Privacy Policy

MOST AMAZING PLACES TANITIM VE TİCARET A.Ş. 

Privacy and Cookie Policy


table of contents


CUSTOMER PERSONAL DATA CLARIFICATION TEXT

This clarification text is the 10th of the Personal Data Protection Law No. 6698 ('KVKK'). In accordance with the provisions of the article and other relevant legislation; MOST AMAZING PLACES TANITIM VE TİCARET A.Ş. as the data controller. STI. Prepared by ('Company'). Within the scope of our company's activities, your personal data, which is required to be collected regarding your customer title, is collected and processed by us in accordance with the provisions of the relevant legislation and the principles described below.

 

1. Method of Collection of Your Personal Data and Legal Reason

Your personal data, in the form of oral and written registration in the physical environment by our field employees who provide office and tourism guidance services, through the sharing or viewing permission given by the internet-based information systems belonging to tourism companies that are our business partners or suppliers in the electronic environment, in the electronic environment, in the call center, telephone, fax, e-mail, website (via online reservation form, e-mail contact forms, cookies and similar technologies) and instant messaging tools in the form of oral, written, auditory and visual recording in the form of digital image recording related to security cameras in the electronic environment, in the service units of our Company, or data recording in the form of digital image recording. It is collected by non-automatic methods provided that it is part of the system.

In this context, your personal data processed by our Company; Name-surname, T.C. identity number, passport information, picture in the passport photocopy, accommodation address, e-mail address, phone number, bank-credit card information, payment receipt and slip contents, invoice, call center voice recording, security camera image records and website IP and cookie information received during the entrance and stay of our workplaces and add-ons. No special quality personal data is collected by our company.

Your data collected for obtaining marketing, analysis and electronic message sending approval from your personal data is processed based on your explicit consent statement given in an enlightened manner specified in Article 5/1 of the KVKK. Your data about your security camera video records taken at the entrance to and stay of our company's workplaces are processed due to the fact that data processing is mandatory for the legitimate interests of our Company in Article 5/2-f of the KVKK.

Your other personal data is processed by our Company based on the legal reasons specified in Article 5/2 of the KVKK and shown below. Your personal data within this scope;

  • It is necessary to process your personal data as the other party of the contract, provided that it is directly related to the establishment or performance of the commercial contract to which you are a party with our company,
  • It is clearly stipulated in the laws or that it is mandatory for our Company to fulfill its legal obligations,
  • Data processing is mandatory for the establishment, use and protection of a right belonging to our company,
  • Data processing is mandatory for the legitimate interests of our Company, provided that it does not harm the fundamental rights and freedoms of your Party,

It is collected and processed based on legal reasons.

 

2. Purpose and Procedure of Processing Your Personal Data

Your personal data Within the scope of the realization of our domestic-international commercial activities by our company; execution of contract and performance processes; goods and service purchase, sale and marketing transactions; after-sales performance and support services; finance and accounting transactions; ensuring information and physical space security; performance of legal processes and obligations arising from legislation; increasing customer satisfaction; giving the commercial supply carried out by our company in the best conditions, providing special goods and services to you in this context with the determination of personalized tastes, needs and usage purposes; raising quality standards; management of market research, analysis, marketing, re-mar/digital marketing processes related to our field of activity; advertising, promotion, offering and satisfaction with activities in our field of activity For the research, general or private e-mail, instant message, voice call is processed in connection with the purpose of the relationship you have established with our Company in order to provide our legal application and defense rights and follow-up of requests and complaints.

Your personal data collected by our company is 4 of the KVKK specified below. It is processed in accordance with the general principles regulated in the article. In this context, your personal data in question;

  • A) In accordance with the law and honesty rules,
  • b) Accurate and up to date when necessary,
  • C) For specific, explicit and legitimate purposes,
  • D) Connected, limited and measured for the purpose for which they are processed,
  • E) It is processed in accordance with the storage rules stipulated in the relevant legislation or for the necessary period for the purpose of processing.

You can access more detailed information about the processing principles of your personal data that you share with our company from our company's "Personal Data Protection and Processing Policy".

 

3. Scope, Duration and Security of Processing Your Personal Data

The nature of the processing of your personal data provided by our Company as stated above; It is limited to be recorded, stored, stored, backed up, changed, rearranged/updated, disclosed, taken over, made available, classified or prevented from being used by our relevant departments and transferred to third parties with whom we have a business relationship within the scope specified below.

Our company keeps the personal data it processes confidentially in accordance with the provisions of the legislation in accordance with Article 12 of the KVKK in a physical environment, database and systems by taking all the necessary technical and administrative measures within the framework of technological methods and within the framework of information security standards. Upon the disappearance of the reasons that require the processing of your personal data in question or the expiration of the destruction periods determined in the relevant legislation and the Policy regulated by our Company in this regard, in accordance with the provisions of the relevant legislation and our "Personal Data Storage and Destruction Policy" text, it destroys it spontaneously or by deletion, destroying or anonymizing it immediately at the request of the data owner.

 

4. To Whom and For What Purpose Your Processed Personal Data May Be Transferred

Your personal data collected by our company, only in accordance with our commercial activity, for the purposes of planning and execution of our Company's business strategies and processes and internal trade processes, establishment and performance of our contracts, execution of post-contractual support services, secure backup/storage of data, making payment and accounting transactions, for the relevant departments of the Company, group companies, business partners, suppliers, service providers, their officials or employees, relevant bank branches, legally authorized institutions and organizations and private legal entities of the KVKK 8 and 9th. It can be transferred domestically or internationally when necessary in accordance with all regulations within the framework of the personal data transfer conditions and purposes specified in the other legislation related to its articles.

In this context, in accordance with the decision of the Personal Data Protection Board dated 31.05.2019 and numbered 2019/157, it should also be taken into account that the personal data subject to the said transmission is deemed to have been transferred abroad when foreign e-mail server and similar systems are used during data transmission.

 

5. Rights You Have Within the Scope of KVKK

In accordance with Article 11 of the KVKK, you have the following rights regarding your personal data:

  • A) To learn whether your personal data is processed,
  • B) If your personal data has been processed, requesting information about it,
  • C) To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
  • ç) To know the third parties to whom your personal data is transferred at home or abroad,
  • D) Requesting correction of your personal data in case of incomplete or incorrect processing,
  • E) In accordance with Article 7 of the KVKK, to request the deletion or destruction of the reasons that require the processing of your personal data, which has been processed in a legal way, disappear,
  • F) Requesting that the transactions made in accordance with subparagraphs (d) and (e) be notified to the third parties to whom your data is transferred,
  • G) Objecting to the emergence of a result against you by analyzing your processed data exclusively through automated systems,
  • ğ) To request compensation for the damage in case you suffer damage due to the unlawful processing of your personal data.
  • H) To withdraw your consent statement regarding the processing of your personal data and your consent to send you electronic commercial messages at any time without giving any reason.

 

6. Ways of Application to Our Company within the Scope of Your Rights

Your requests within the scope of the exercise of your above-mentioned rights, by filling out the "Personal Data Owner Application Form" on the most-amazing-places.com page according to the "Communiqué on the Procedures and Principles of Application to the Data Controller" or with a similar petition, our Company "Gümüşsuyu Mah. İnönü Cad. Melek Apt. No: 11/2 Beyoğlu/ISTANBUL" address you can apply in person and send it by identity card or in writing via Notary Public or via registered/secure e-mail to "info@most-amazing-places.com" as an e-mail.

Depending on the nature of your request, your applications will be finalized 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 charged according to the tariff to be determined by the Personal Data Protection Board.

SUPPLIER AND BUSINESS PARTNER PERSONAL DATA CLARIFICATION TEXT

 

This clarification text is the 10th of the Personal Data Protection Law No. 6698 ('KVKK'). In accordance with the provisions of the article and other relevant legislation; MOST AMAZING PLACES TANITIM VE TİCARET A.Ş. as the data controller. STI.(“ Company”) was prepared by Within the scope of our company's activities, your personal data, which is required to be collected regarding your supplier or business partner, is collected and processed by us in accordance with the provisions of the relevant legislation and the principles described below.

 

1. Method of Collection of Your Personal Data and Legal Reason

Your personal data is collected by our employees in the form of oral, written, audio recording and image recording through the channel, which is contacted by oral and written recording in the phone, fax, e-mail, website (via e-mail communication forms, cookie, etc. technologies) and instant messaging and video conversation tools, and in the service units of our company, in the form of digital image recording of security cameras, or by non-automatic methods, provided that it is part of the data recording system.

In this context, your personal data processed by our Company in terms of our suppliers and business partners and their authorized or employees; Name-surname, T.C. ID number, passport information, address, e-mail address, phone and fax number, real person business/commercial title, tax administration and number, bank account and IBAN number, bank-credit card information, check-bill information, waybill, invoice, payment receipt and slip contents, current account information, signature data, call center voice recording, security image camera records and website IP and cookie information taken during the entrance and stay to our workplaces and add-ons.

In this context, your special quality personal data processed by our Company in terms of the authorized or employees of our suppliers and business partners; It is your biometric data regarding the image recording obtained through internet-based platforms used to work with the video conferencing method. Apart from this, your special quality personal data is not processed by our Company in any way.

Your data collected from your personal data for obtaining special marketing, analysis and electronic message sending approval to you is collected and processed based on your explicit consent statement given in the illuminated manner specified in Article 5/1 of the KVKK. Your data about your security camera video records taken at the entrance to the workplaces and add-ons of our company and during the stay there is processed due to the fact that data processing is mandatory for the legitimate interests of our Company regulated in Article 5/2-f of the KVKK. Your biometric data regarding the image recording obtained through the internet-based platforms used during remote operation are processed based on the legal reason for your explicit consent statement in accordance with Article 6/3-a of the KVKK.

Your other personal data is processed by our Company based on the legal reasons specified in Article 5/2 of the KVKK and shown below. Your personal data within this scope;

  • It is necessary to process your personal data as the other party of the contract, provided that it is directly related to the establishment or performance of the commercial contract to which you are a party with our company,
  • It is clearly stipulated in the laws or that it is mandatory for our Company to fulfill its legal obligations,
  • Data processing is mandatory for the establishment, use and protection of a right belonging to our company,
  • Data processing is mandatory for the legitimate interests of our Company, provided that it does not harm the fundamental rights and freedoms of your Party,

It is collected and processed based on legal reasons.

 

2. Purpose and Procedure of Processing Your Personal Data

Your personal data obtained in the form described above is within the scope of the realization of our domestic-international commercial activities by our Company; execution of contract and performance processes; planning and follow-up of the works carried out with business partners and suppliers; purchase and sale of goods and marketing transactions; after-sales performance and support services; finance and accounting transactions; ensuring information and physical space security; performance of legal processes and obligations arising from legislation; giving the commercial supply carried out by our company in the best conditions; working with the video confencing method in order to carry out of works uninterruptedly in unusual times such as epidemics; raising quality standards; management of market researches, analysis, marketing, re-digital marketing processes related to our field of activity; in our field of activity For the activities and advertising, promotion, offering and satisfaction research, sending general or private e-mail, instant message, voice call; It is processed in connection with the purpose of the relationship you have established with our Company in order to provide our legal application and defense rights and to follow up requests and complaints.

Your personal data collected by our company is the 4th of the KVKK specified below. It is processed in accordance with the general principles regulated in the article. In this context, your data in question;

  • A) In accordance with the law and honesty rules,
  • b) Accurate and up to date when necessary,
  • C) For specific, explicit and legitimate purposes,
  • D) Connected, limited and measured for the purpose for which they are processed,
  • E) It is processed in accordance with the rules of keeping it for the period stipulated in the relevant legislation or required for the purpose for which it is processed.

You can access more detailed information about the processing principles of your personal data that you share with our company from our company's "Personal Data Protection and Processing Policy".

 

3. Scope, Duration and Security of Processing Your Personal Data

The nature of the processing of your personal data provided by our Company as stated above; It is limited to be recorded, stored, stored, backed up, changed, rearranged/updated, disclosed, taken over, made available, classified or prevented from being used by our relevant departments and transferred to third parties with whom we have a business relationship within the scope specified below.

Our company keeps the personal data it processes confidentially in accordance with the provisions of the legislation in accordance with Article 12 of the KVKK in a physical environment, database and systems by taking all the necessary technical and administrative measures within the framework of technological methods and within the framework of information security standards. In the event that the reasons that require the processing of your personal data that is retained are eliminated or if the destruction periods determined in the relevant legislation and the Policy regulated by our Company on this subject, it destroys it by itself or by deleting, destroying it spontaneously or by anonymizing it at the request of the data owner in accordance with the provisions of the relevant legislation and our "Personal Data Storage and Destruction Policy".

 

4. To Whom and For What Purpose Your Processed Personal Data May Be Transferred

Your personal data collected by our company, only as a requirement of carrying out our commercial activity, for the purpose of planning and execution of our Company's business strategy and processes and internal trade processes, establishment and performance of our contracts, execution of post-contractual support services, secure backup/storage of data, making payment and accounting transactions, our shareholders, group companies, business partners, suppliers, service providers, their officials or employees, relevant bank branches, your financial advisor or accounting department, legally authorized institutions and organizations and private legal entities for the purposes of KVKK 8 and 9th. It can be transferred domestically or internationally when necessary in accordance with all regulations within the framework of the personal data transfer conditions and purposes specified in the other legislation related to its articles.

In this context, it should also be taken into account that when foreign mail server and similar systems are used during the data transmission during the decision of the Personal Data Protection Board dated 31.05.2019 and numbered 2019/157, it should also be taken into account that the personal data subject to the said transmission is considered to have been transferred abroad, with the audio and biometric data on audio and video recording obtained through internet-based overseas-based platforms used during the work with the video conferencing method.

 

5. Rights You Have Within the Scope of KVKK

In accordance with Article 11 of the KVKK, you have the following rights regarding your personal data:

  • A) To learn whether your personal data is processed,
  • B) If your personal data has been processed, requesting information about it,
  • C) To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
  • ç) To know the third parties to whom your personal data is transferred at home or abroad,
  • D) Requesting correction of your personal data in case of incomplete or incorrect processing,
  • E) Within the framework of the conditions stipulated in Article 7 of the KVKK, requesting the deletion or destruction of the reasons that require the processing of your personal data, which has been processed legally, disappear,
  • F) To request the notification of the transactions made in accordance with subparagraphs (d) and (e) to the third parties to whom your personal data has been transferred,
  • G) Objecting to the emergence of a result against you by analyzing your processed data exclusively through automated systems,
  • ğ) To request compensation for the damage in case you suffer damage due to the unlawful processing of your personal data.
  • H) To withdraw your consent statement regarding the processing of your personal data and your consent to send you electronic commercial messages at any time without giving any reason.

 

6. Ways of Application to Our Company within the Scope of Your Rights

Your requests within the scope of the exercise of your above-mentioned rights, by filling out the "Personal Data Owner Application Form" on the most-amazing-places.com page according to the "Communiqué on the Procedures and Principles of Application to the Data Controller" or with a similar petition, our Company "Gümüşsuyu Mah. İnönü Cad. Melek Apt. No: 11/2 Beyoğlu/ISTANBUL" address you can apply in person and send it by identity card or in writing via Notary Public or via registered/secure e-mail to "info@most-amazing-places.com" as an e-mail.

Depending on the nature of your request, your applications will be finalized 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 charged according to the tariff to be determined by the Personal Data Protection Board.

WEBSITE COOKIE CLARIFICATION TEXT 

This text is MOST AMAZING PLACES TANITIM VE TİCARET A.Ş. as the data controller within the scope of Article 10 of the Personal Data Protection Law (KVKK) No. 6698 and the Communiqué on the Procedures and Principles to be Followed in the Fulfillment of the Clarification Obligation. STI. Prepared by ('Company').

 

1. OBJECTIVE

The purpose of this Cookie Clarification Text is to inform you about the processing of personal data obtained automatically through the placement of the cookies used on our website on your device, for what purposes what types of cookies we use, the legal reason and your rights. Thus, it is also possible to manage your privacy preferences in accordance with the European Union General Data Protection Regulation (EU General Data Protection Regulation: 'GDPR').

 

2. DATA PROCESSED THROUGH COOKIE DESCRIPTION, PURPOSE OF USE AND COOKIES

A cookie is a small text file that the site saves on your computer or mobile device when you visit a website. These files make it possible to detect your device every time you visit the website, thus allowing you to browse the website and use its resources. The main purpose of the use of cookies is to provide functions such as the proper functioning of a website, improving the user experience, the development of the site and the delivery of more appropriate advertisements based on interest, preventing unnecessary advertising display that will not interest the user.

Through cookie technology, cookie data consisting of information such as the information given by the users of the Site with their consent statements and the preferences made on the site, their reactions to the advertising banners on the site, and information such as IP number and address are processed.

Through this text, it is explained what kinds of cookies are used on our website for what purposes. MOST AMAZING PLACES TANITIM VE TİCARET A.Ş.., we can stop using the cookies we use in our online channels, change their types or functions, or add new cookies to our site. Therefore, we reserve the right to change the provisions of this 'Cookie Clarification Text' when necessary. Any changes made on the current text become effective by being published on the website.

 

3. TYPES OF COOKIES

A) Types of cookies according to the duration of use: The session cookie is used to ensure the continuity of the session, and these cookies are also deleted when the user closes the browser. The permanent cookie, on the other hand, is not deleted when the internet browser is closed and is automatically deleted on a certain date or after a certain period of time. In this context, session and permanent cookies are used on our website according to their usage period.

B) First-party and third-party cookies: First-party cookies are placed directly by the website visited by the user, that is, the address shown in the address bar of the browser. Third-party cookies are placed by a different domain other than the address visited by the user. In this context, only first-party cookies are used on our website.

C) Types of cookies according to the purpose of use: Cookies can be used for absolutely necessary, functional or advertising/marketing purposes according to their intended use. In this context, absolutely necessary cookies are used in order to provide the information society services you have clearly requested on our website.

 

4. COOKIES USED ON OUR WEBSITE

First-party session and persistent cookies are used on our website as absolutely necessary for the provision of information society services. In this context;

A) First-party permanent cookie called Borlabs Cookie - consent (stored for one year) to the website to understand whether the subsequent requests are reliable,

B) First-party permanent cookie called Borlabs Cookie - consent (stored for one year) for the purpose of confirming that the cookie disclosure text has been read.

Your personal data is processed by associating it with your IP information. Your personal data in question is not transferred to other data controllers.

 

5. LEGAL REASON FOR OUR PERSONAL DATA PROCESSING THROUGH COOKIES

In the processing of personal data through the said cookies, in accordance with subparagraph (f) of the second paragraph of Article 5 of the Personal Data Protection Law No. 6698, it is based on the processing condition that "Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person".

 

6. THIRD PARTY SITE, PRODUCTS AND SERVICES

The company's website may contain links to third parties' website, products and services. Such links accessed from our site are subject to third parties' privacy-security, use and personal data processing policies, and it should be aware that third parties and third parties' sites are independent of the Company and the Company is not responsible for these third parties' specified practices. In case of visiting the linked websites, we recommend that the privacy policies of these sites be read.

Because our Company is not responsible for disputes, material-moral damages and losses that may occur due to the personal data and information processing and use of the Websites, ethical principles, privacy-security principles, service quality, terms of use and other practices of the websites in question, which are reached for advertising, banners, content or for any other purpose. They are responsible for the information that data owners obtain from our site or other sites linked to on our site, information, promotion and advertisements that are communicated electronically to their parties, as well as the decisions they make within the framework of all kinds of suggestions, and all kinds of transactions and applications they make according to them.

 

7. WAYS TO APPLY TO OUR COMPANY WITHIN THE SCOPE OF YOUR RIGHTS

You can submit your requests within the scope of Article 11 of the KVKK, "Regulating the rights of the relevant person", by filling out the "Personal Data Owner Application Form" on the "most-amazing-places.com" page according to the Communiqué on the Procedures and Principles of Application to the Data Controller, or with a similar petition, our Company "Gümüşsuyu Mah. İnönü Cad. Melek Apt. No: 11/2 Beyoğlu/ISTANBUL" address you can apply in person and send it by identity card or in writing via Notary Public or via registered/secure e-mail to "info@most-amazing-places.com" as an e-mail.

PERSONAL DATA PROTECTION AND PROCESSING POLICY

Version 1.0

01.06.2024.

1. LOGIN

1.1. Purpose

This Personal Data Protection and Processing Policy ('Policy'), as the data controller, MOST AMAZING PLACES TANITIM VE TİCARET A.Ş.. It has been prepared to determine the procedures and principles regarding the work and transactions related to the personal data processing and protection activities carried out by the ("Company").

Our company; in line with the basic principles it has adopted; Company employees, former employees, employee candidates, shareholders, customers, potential customer candidates, service providers, suppliers, business partners, their officials and employees, visitors and other relevant third parties T.C. It has determined as a priority that it is processed and protected in accordance with the Constitution, international conventions, the Law on the Protection of Personal Data No. 6698 ('KVKK') and other relevant legislation, and to ensure that the relevant persons use their rights effectively in this regard.

The work and transactions related to the processing and protection of personal data are carried out in accordance with the Policy prepared by the Company accordingly. Thus, the Company provides the necessary transparency by informing the personal data owners and showing all their rights and application procedures and ways of their use. With the full awareness of our responsibility in this context, your personal and private personal data is processed and protected by us within the scope of this Policy.

 

1.2. Scope

All personal data belonging to Company employees, former employees, employee candidates, shareholders, customers, potential customer candidates, service providers, suppliers, business partners and their officials and employees, visitors and other third parties who establish a relationship with our Company, or processed by non-automatic means, provided that they are part of any data recording system, are covered by this Policy. This Policy is applied to all recording media such as physical, electronic, website and social media, where personal and special quality personal data owned or managed by the Company are processed, and this Policy applies to all activities for personal data processing.

With the KVKK, special importance has been attached to some personal data due to the risk of causing victimization or discrimination of people if it is processed illegally. These data; They are special quality personal data described in the Abbreviations and Definitions Table below. It is treated sensitively by our company in the protection of special quality personal data determined as "special quality" with the KVKK and processed in accordance with the law. In this context, the technical and administrative measures taken by our Company for the storage and protection of personal data are applied much more carefully in terms of special quality personal data, and some additional measures specified in sections 4.3. and 4.5.2. below are also taken for their processing, and necessary audits are also provided within the Company.

However, depending on the type and nature of the relationship between our company and the data subject, it is possible to provide data subjects with personal data policies and/or notifications, clarification texts procedures different from this Policy by our company. Such special policy and disclosure texts/notifications provided to data owners may also be in addition to the explanations in this Policy. In this case, such special policies and notifications provided to data owners should be taken into account first. In addition, the relevant legal regulations in force regarding the processing and protection of personal data will first find application. In the event of a non-compliance between the applicable legislation and the Policy, our Company accepts that the current legislation will first find application. The policy aims to regulate the rules set forth by the relevant legislation by embodying them within the scope of Company practices.

 

1.3. Abbreviations and Definitions

Buyer Group

The category of natural or legal person to whom personal data is transferred by the data controller.

Open Consent

Consent on a particular subject, based on information and explained by free will.

Anonymizing

 

Making personal data unidentified or identifiable natural person in any way by matching it with other data.

Employee / Former Employee

 

MOST AMAZING PLACES TANITIM VE TİCARET A.Ş.. staff/staff leaving the job.

Employee Candidate

MOST AMAZING PLACES TANITIM VE TİCARET A.Ş.. People who have not been contrected with employment but are evaluated for establishment.

Electronic Media

 

Environments where personal data can be created, read, changed and written with electronic devices.

Non-Electronic (Physical) Media

All written, printed, visual, etc. other media except electronic media.

Service / Expertise Service Provider

 

MOST AMAZING PLACES TANITIM VE TİCARET A.Ş.. A real or legal person who provides a service or specialized service such as accounting, workplace health-safety, informatics, law within the framework of a certain contract with.

Contact Person

The natural person whose personal data is processed.

Related Employee

 

Persons who process personal data within the data controller organization or in line with the authority and instructions received from the data controller.

Destruction

 

Deletion, destruction or anonymization of personal data.

Law

Law No. 6698 on the Protection of Personal Data.

Recording Media

 

Any environment in which there is personal data that is completely or partially automatic or processed by non-automatic means, provided that it is part of any data recording system.

Personal Data

 

Any information about an identified or identifiable natural person.

Personal Data Processing Inventory

 

The personal data processing activities that data controllers carry out depending on their business processes; the personal data processing purposes and legal reason, the data category, the transferred recipient group and the data subject person group create by and the inventory they detail by explaining the maximum retention period required for the purposes for which the personal data is processed, the personal data foreseen to transfer to foreign countries and the measures taken regarding data security.

Processing of Personal Data

 

All kinds of operations performed on data such as obtaining, recording, storing, storing, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data completely or partially automatic or by non-automatic means, provided that it is part of any data recording system.

Board

Personal Data Protection Board

KVKK

Law No. 6698 on the Protection of Personal Data

Special Quality Personal Data

 

Data on race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing, membership of association, foundation or union, health, sexual life, criminal conviction and security measures, and biometric and genetic data of the person.

Periodic Destruction

 

In case the conditions of processing personal data in the law disappear, the process of deletion, destruction or anonymization specified in the personal data storage and destruction policy and will be carried out ex officio at repeated intervals.

Politics

PERSONAL DATA PROTECTION AND PROCESSING POLICY.

Company

MOST AMAZING PLACES TANITIM VE TİCARET A.Ş..

Data Processor

 

A natural or legal person who processes personal data on behalf of the data controller based on the authority given by the data controller.

Data Recording System

 

Registration system in which personal data is structured and processed according to certain criteria.

Data Owner

The natural person whose personal data is processed.

Data Controller

 

A natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

Data Controllers Registry Information System (VERBIS)

 

The information system created and managed by the Personal Data Protection Board, which can be accessed over the internet, which can be used by data controllers in the application to the Registry and other relevant transactions related to the Registry.

VERBIS

Data Controllers Registry Information System

 

2. DATA RESPONSIBLE

MOST AMAZING PLACES TANITIM VE TİCARET A.Ş.. in the processes related to your personal data. STI. Acts as a data controller according to Law No. 6698. As the data controller, we are responsible and responsible for determining the purposes for processing your personal data and by what means it will be processed. In this context, this Policy text has been prepared to inform you in detail about the Company's data processing purposes, means and protection methods.

3. RESPONSIBILITY AND DUTY DISTRIBUTIONS

All units and employees of the company actively support the responsible units in order to implement the technical and administrative measures taken within the scope of the Policy by the responsible units, to increase the training and awareness of the unit employees, to monitor and to prevent the unlawful processing of personal data, to prevent unlawful processing of personal data, and to ensure that personal data is kept in accordance with the law, in order to take all necessary technical and administrative measures to ensure that personal data is processed.

On the other hand, regarding the personal data processed by our Company, both the data controller official and employees acting as the data controller, and the persons who process the data as a result of the transfer on behalf of our Company, cannot disclose the personal data they have learned to anyone else in violation of the provisions of this Policy Text and the KVKK, and cannot use it for other than the purpose of processing. This obligation is the 12/4 of the KVKK. In accordance with the article, it continues indefinitely/lifetime after the end of the task/work.

The distribution of the titles, units and job descriptions of the personal data processing, storage and destruction processes is given in Table 1.

Table 1: Storage and disposal processes task distribution

TITLE

UNIT

DUTY

Company Personal Data Controller Officer

MOST AMAZING PLACES TANITIM VE TİCARET A.Ş..

It is responsible for preparing, developing, executing the policy, publishing and updating it in relevant environments and the employees acting in accordance with the policy.

Company Data Controller Contact Person

Administrative and Financial Affairs

It is responsible for the provision and follow-up of the administrative, physical and technical solutions needed in the implementation of the policy.

Finance and Accounting, Procurement, Sales, Marketing and Regional Operations, Computing (IT), Departments

Other Units

He is responsible for the execution of this Policy in accordance with his duties.

 

4. ISSUES CONCERNING THE PROCESSING OF PERSONAL DATA

4.1. Processing of Personal Data in Accordance with the Principles Stipulated in the Legislation (Processing Conditions)

4.1.1. Processing in accordance with the Law and the Rule of Honesty

Personal data is not harmed by the fundamental rights and freedoms of the persons (i.e., especially the 4th of the KVKK). Article et al. is processed in accordance with the general trust and honesty rule in a way that is not contrary to other legislation related to In this context, personal data is processed in the minimum amount and extent required by our Company's business activities and limited to.

In accordance with this principle, the obligation to act in accordance with the principles brought by the laws and other legal regulations in the processing of personal data and the prohibition of not abuse of the right is carefully complied with by our Company. In accordance with the principle of compliance with the rule of honesty, our Company also takes into account the interests and reasonable expectations of the relevant persons while trying to achieve its goals in data processing. It acts in a way that prevents the emergence of results that the person concerned does not expect and does not need to wait. In accordance with this principle, the data processing activity in question is also carried out for the relevant persons, as transparent and in accordance with the information and warning obligations.

To reignterate, in accordance with the honesty rule of our Company, maximum attention is paid to the fact that the personal data of the relevant person should not be used in a way that leads to injustice to the relevant person, to meet the reasonable expectations of the relevant person and not to exceed the purpose of collection of personal data. Again, in this context, for example; According to the nature of the relationship established with the data owner, it is acted in accordance with the requirements of the honesty rule, such as that the unreasonable data is not requested and processed from the relevant person within the relevant person within the framework of the confidentiality, and that the personal data is not processed by more employees than necessary within our Company.

 

4.1.2. Ensuring Personal Data is Accurate and Up-to-Date When Needed

Our company takes the necessary measures to be accurate and up-to-date during the processing of personal data and carries out the necessary studies to ensure the accuracy and up-to-dateness of personal data for certain periods of time. In this context; Necessary care is taken in matters such as determining the sources from which personal data is obtained, and testing the accuracy of them when necessary, and considering the requests arising from the inaccurity of personal data.

Because this principle is in accordance with the right of the relevant person stipulated in the KVKK to request the correction of the data. Keeping personal data accurate and up-to-date is necessary for the benefit of our Company, as well as for the protection of the fundamental rights and freedoms of the data owner and for the prevention of material-moral damage. For example, in the event that a person whose contact information was registered incorrectly cannot receive his messages in a timely manner or if they were sent to an incorrect person, the person concerned may be damaged materially and morally. Again, the correct and up-to-date information of the number of children of an employee or the working status of his spouse is important for the correct calculation of the minimum living allowance (AGI). Our obligation to actively care to ensure that personal data is accurate and up-to-date when necessary; It is valid by our Company if a result is revealed regarding the data subject based on this data (for example, situations such as lending transactions). Apart from this, as the data controller, our Company always keeps the channels open to ensure that the information of the relevant person is accurate and up-to-date.

 

4.1.3. Processing for Specific, Clear and Legitimate Purposes

Before the personal data processing activity, our company carries out data processing by fulfilling all necessary clarification notifications regarding the personal data processing in appropriate ways in channels where both physical and electronic data are recorded, and, when necessary, the processing of consent. Thus, what are the personal data subject to the processing before the transaction by our Company, the methods by which they are obtained and the purposes of processing are clearly and precise, and in line with the business, trade and service activities carried out by our Company, the data is processed within the scope of certain, clear and legitimate purposes related to these activities. For example, our Company does not process personal data that is not related to our business at any time or way, such as the mother's maiden name, in all sales and customer relations processes.

In this context, it is ensured that personal data processing activities are clearly understandable by the person concerned, that the personal data processing activities are carried out on the basis of which legal processing conditions are carried out, and that the personal data processing activity and the purpose of carrying out this activity are revealed in detail. Therefore, the personal data obtained are not processed for purposes other than the purposes of issuance or by misusing in any way.

 

4.1.4. Being Linked, Limited and Measured to the Purpose for Which They Are Processed

Our company collects personal data only to the nature and extent required by business activities and processes it limited and in connection with the purposes of giving. In this context, in accordance with the principle of being connected and limited to the purpose; Care is taken to ensure that the processed data is necessary and convenient for the realization of the determined current and current purposes, and to avoid the processing of personal data that is not related or needed to the realization of such purpose. Because other than what is necessary for the purpose, data processing will constitute a violation of the principle of limitation. For example, sending an advertisement to the email address given to participate in a symposium is against the principle of being limited.

In accordance with the principle of proportionality; We take into account that a reasonable balance should be established between data processing and the purpose to be realized. In other words, we carry out our data processing activity only to the extent that it fulfills the purpose. For example, no data subject is asked by our Company about their preferences for their social life in any process.

 

4.1.5. Retaining for the Time Required for the Purpose Prescribed or Processed in the Relevant Legislation

Personal data should be kept as a requirement of the 'limitation principle for the purpose' only in accordance with the period required for the purpose for which they are processed. In accordance with this principle, our Company does not store personal data after the specified period has expired, the purpose is realized or the data processing condition has disappeared, for the purpose of use it for another purpose or based on the existence of the possibility of using it in the future, and it rests the necessary ways to go to the necessary ways of destruction. For example, if there is no other processing requirement, the name and license plate information collected for participation in a campaign to be awarded to those who receive a certain amount of products in a certain period of time, if there is no other processing requirement, issues such as no longer being used and destroyed at the end of the campaign are carefully followed.

In this regard, as stated in Article 12 of the KVKK, our Company takes all kinds of technical and administrative measures to ensure the appropriate operational and security level in order to prevent the unlawful processing of personal data, to prevent unlawful access to personal data and to ensure the preservation and destruction of personal data when necessary.

In this context, our Company retains personal data for the minimum period stipulated in the relevant legal legislation, which is necessary for the purpose for which they are processed. In the specified direction, our Company first determines whether a period is foreseen for the storage of personal data in the relevant legislation, and acts in accordance with this period if a period is determined. If there is no legal period, personal data is stored for the period necessary for the purpose for which the data is processed, taking into account the storage periods determined according to the field of activity of our Company. Personal data is destroyed at the end of the specified retention periods in accordance with the periodic destruction periods or the data owner application and by the determined destruction methods (deletion, destruction or anonymization). In addition to this Policy text, you can find more detailed information about the issues related to storage and destruction in the "Personal Data Storage and Destruction Policy" text to be found on our Company's website most-amazing-places.com.

 

4.2. Legal Reasons for Processing Personal Data

Apart from the express consent of the personal data owner, the basis of the personal data processing activity may be only one of the following conditions, and more than one condition may be the basis of the same personal data processing activity. If the processed data is special quality personal data, additional conditions in sections 4.3. and 4.5.2 of this Policy will also apply.

 

4.2.1 Explicit Consent of the Personal Data Owner

The explicit consent of the data owner is one of the conditions of personal data processing. However, if the personal data processing activity is based on one of the conditions other than the express consent specified in the following articles in the KVKK, our Company takes care to carry out data processing activities based on the provisions of the specified law only by fulfilling the obligation to clarify in all circumstances, since there is no need to obtain explicit consent from the relevant person and the priority must be given to the conditions other than these specified consent.

In cases where there are no provisions of the law regarding this specified data processing or do not allow the processing of personal data sufficiently, personal data is processed by our Company based on the explicit consent of the data owner. In this case, maximum attention and care is taken to the fact that the explicit consent of the data owner is disclosed on a certain subject, based on information and with free will. Again, during data processing based on explicit consent, the disclosure notification is fulfilled regardless of this and before, and in this way, consent is obtained in an illuminated way. Likewise, the process of obtaining explicit consent for data processing is not made a prerequisite for the provision of any goods or services and is carried out in such a way that does not include a situation that will be to the disadvantage of the data owner if explicit consent is not given.

To emphasize again, in the presence of any of the following personal data processing conditions, personal data will be processed based on these conditions specified by our Company without the need for the explicit consent of the data owner.

 

4.2.2 Clearly Stipulated In Law

If the processing of the personal data of the data subject is clearly stipulated in the law or in other words, if there is a clear provision regarding the processing of personal data in the relevant law such as Tax Laws, Labor Law, Commercial Law and KVKK, the existence of this data processing condition can be mentioned. For example, in accordance with the Labor Law, the personal information and file of our employees or the tax numbers of our customers in accordance with the financial legislation, receiving and keeping them are within this scope.

 

4.2.3 Failure to Obtain the Explicit Consent of the Relevant Due to the Actual Impossibility

The personal data of the data subject may be processed if the processing of his personal data is mandatory in order to protect the life or physical integrity of himself or another person who is unable to express his consent due to the actual impossibility or who does not have the power to distinguish between his consent. For example, the processing of the personal health information of the unconscious person or the contact and location information of the pledge person falls within this scope.

 

4.2.4 Directly Related to the Establishment or Execution of the Contract

Provided that it is directly related to the establishment or performance of a contract, if the processing of personal data belonging to the parties of the contract is mandatory, this condition will be deemed fulfilled in case of processing the data for this purpose, limited to this purpose. For example, Labor Contract, Sales Contract, Transport Agreement, Service Agreement, etc. As a result of legal relations such as, recording the address information for service/product performance, giving them to the transportation company or requesting a document showing the training status from the Company employee fall within this scope. Again, cases such as obtaining the account number of the creditor party for paying money or salary payment to the employee in accordance with a contract, or the Company obtaining the salary payroll, title deed records and document of that there is no enforcement debt of that person during the conclusion of a surety contract.

Sometimes there may be multiple legal reasons for personal data collection. For example, although the legal basis for the processing of the personal data of the employees in order to regulate the payroll is within the scope of this article, this situation is also the reason for the fulfillment of our Company's legal obligation, which will be mentioned below.

 

4.2.5 Fulfillment of our Company's Legal Obligations

If data processing is mandatory for our company to fulfill its legal responsibilities and obligations, the personal data of the relevant person may be processed. For example, data processing enters here due to the obligation to share information for situations such as financial audits, security legislation, compliance with sector-oriented regulations. In this context, the acquisition and processing of data such as bank account number, whether he is married, dependents, whether his spouse works, and social insurance number to pay a salary to our employees can be given as an example of this situation. It can also be evaluated within this scope that our company submits information about its employees or customers to the examination of the relevant public officials during the tax audit.

 

4.2.6 The Personal Data Owner's Selicization of Personal Data

If the data owner has made his personal data public, that is, he submits his/her information to the public with the will to publicize it and for certain purposes, the relevant personal data may be processed limitedly for the purpose of publicization. Since the fact that a person's personal data is in a place where only everyone can see for reasons such as coincidence or loss will not make it public, data processing is carried out by paying attention to the detail in this regard. In addition, in case of publication, the rule of not using personal data for other than its purpose is followed. For example, it is taken into account that the contact information of the relevant people on the websites where vehicles are purchased and sold cannot be used and processed for marketing purposes.

An example of this situation can be given to a person publicly announce his contact information in order to contact him in certain situations. On corporate websites, if the employees' workplace phone numbers and corporate e-mail addresses are shared openly to third parties, it can be mentioned without publicization. Again, for example, the contact information of the person who made an advertisement containing the supply or demand of goods or services related to the field of activity of our Company may be processed in order to use it within this scope.

 

4.2.7 Data Processing is Mandatory for the Establishment or Protection of a Right

If data processing is mandatory for the establishment, use or protection of a right such as resorting to legal action for our company, the personal data of the data subject may be processed. These data, filing a lawsuit, registration transactions, all kinds of title deed transactions, etc. These are mandatory data to be used in works such as For example, it is here that some personal data and information of an employee leaving the job are kept for 10 years of time for the purpose of using it as evidence in a lawsuit to be opened. Similarly, after the end of the contract, the storage of documents such as invoices, contract copies, surety for these purposes until the end of the statute of limitations against possible lawsuits or legal proceedings will be evaluated within this scope.

 

4.2.8 Data Processing is Mandatory for the Legitimate Interest of Our Company

Provided that it does not harm the fundamental rights and freedoms of the personal data owner, the personal data data owner may be processed if data processing is mandatory for the current, important/serious and legitimate interests of our Company. In this context, for example, our Company's personal data within these scopes may be processed, provided that it does not harm the fundamental rights and freedoms of our employees, to be based on their promotions, salary increases or social rights, or in the distribution of duties and roles in the process of restructuring the enterprise. Again, for example, data processing is carried out in this scope in order to record camera images for security purposes in the workplaces of our Company or to apply rewards and premiums that increase the loyalty of our employees.

In order for this Article to be implemented, we consider that a reasonable balance should be achieved between the legitimate interest of our Company and the rights and freedoms of the data subject. However, when making this evaluation, it should also be taken into account that the legitimate interest of our Company and the purpose of processing personal data should not be confused. The purpose of processing personal data is specifically related to the reason for the processing of the data. However, in this context, the legitimate interest of our Company as the data controller is in a position to be interpreted more broadly, as it is found for the benefit to be obtained as a result of the data processing activity to be carried out.