Privacy Policy for WorkInn Hotel

WORKINN HOTEL PERSONAL DATA PROTECTION LAW

INFORMATION NOTICE

TRANSVARO ELECTRONIC DEVICES INDUSTRY AND TRADE INC. (“WORKINN HOTEL”) takes the highest possible security measures to ensure that your personal data is collected, stored, and shared in accordance with the law, and to protect your privacy.

Our aim is to inform you in the most transparent way about the methods of collecting your personal data, the purposes of processing, the persons with whom the data is shared, legal reasons, and your rights in accordance with Article 10 of the Personal Data Protection Law No. 6698, and in line with your satisfaction.

a) Data Controller
Under the Personal Data Protection Law No. 6698 (“Law No. 6698”), your personal data is collected and processed by TRANSVARO ELECTRONIC DEVICES INDUSTRY AND TRADE INC. (“COMPANY”) as the data controller, as explained below.

b) Purpose of Processing Personal Data
Your personal data is processed for the limited and measured purposes related to the provision of various services such as accommodation, dining, banquets, events, meetings, pool and spa usage (collectively referred to as “Hotel Use”), including but not limited to:

• The execution of services and contracts,
• Identification of hotel usage and expenses,
• Ensuring security and maintaining security records,
• Fulfilling financial obligations,
• Ensuring service quality,
• Fulfilling legal obligations,
• Measuring and increasing customer satisfaction,
• Managing complaints,
• Receiving feedback and suggestions regarding new services and products,
• Receiving reports of issues or errors,
• Providing information on products and services, complaints, and requests,
• Conducting advertising, promotion, and corporate communication activities,
• Preparing the company for internal and external audits,
• Creating sales-related cards for purposes such as promotions, membership, and loyalty,
• Using your personal data for advertising, information, and other purposes within the framework of the Electronic Commerce Regulation Law,
• Analyzing the customer portfolio,
• Conducting traffic measurement, statistical analyses, segmentation/profiling, and CRM activities for sales and marketing,
• Monitoring internet services provided by the COMPANY during your visit under the scope of Law No. 5651,
• Your personal data is processed within the legal relationship established between us due to Hotel Use.

Personal data is also collected through monitoring, observation, surveillance, and recording systems with image features in order to ensure security in corridor areas, common areas, spas, and pool areas, prevent any negative occurrences, or provide information to law enforcement when necessary, identify incidents, inform the necessary persons and institutions, protect against internal and external threats, and improve service quality.

c) Who Personal Data Can Be Transferred To and For What Purpose Your personal data, for the purposes stated in section b) above, may be transferred to:

• The COMPANY's business partners, shareholders, and affiliates,
• Persons or institutions authorized by tax law, social security legislation, the Court of Accounts, the Law on the Prevention of Money Laundering, the Law on the Prevention of Financing Terrorism, the Turkish Commercial Code, the Code of Obligations, and other relevant regulations,
• Authorized public institutions, administrative bodies, and legal authorities,
• Foreign companies and affiliates,
• Real or legal persons with whom we cooperate, provide services, or work, including institutions, companies, and courier services involved in delivering products or services you have ordered.

ç) Method and Legal Basis for Collecting Personal Data
Your personal data is collected both partially or fully through automated methods and through non-automated methods that are part of the data recording system:

• Directly by you or authorized individuals acting on your behalf, via applications made through partner websites, the COMPANY's staff, supported institutions, or any legal or contractual entities, and through direct automated systems (our website, mobile application, call centers, social media accounts) in verbal, written, or electronic environments.

In accordance with Articles 5 and 6 of the Law, personal data is collected based on the following legal grounds:

• When explicitly foreseen in the law,
• When it is necessary for the performance of a legal obligation,
• When processing is directly related to the establishment or performance of a contract,
• When processing is necessary for the legitimate interests of the COMPANY, provided that it does not harm your fundamental rights and freedoms,
• When it has been made public by you,
• When processing is required for the establishment, exercise, or protection of a legal right,
• With your explicit consent.

d) Rights of the Data Subject under Article 11 of the Law No. 6698

As a data subject, you can send your requests regarding your rights to the COMPANY using the methods set out below. The COMPANY will respond to your request in the shortest time possible and within a maximum of thirty days. No fee will be charged for responses up to ten pages. For each page over ten, a processing fee of 1 Turkish Lira will be charged. If the response is provided in a record medium such as CD or USB, the cost of the medium will not exceed the cost of the medium itself.

In this context, data subjects have the right to:

• Learn whether their personal data has been processed,
• Request information about their personal data if processed,
• Learn the purpose of processing and whether the data is used in accordance with its purpose,
• Learn the third parties to whom personal data is transferred,
• Request correction of incomplete or inaccurate data and ask for the third parties to be informed,
• Request deletion or destruction of personal data if the reasons for processing no longer exist, and ask for the third parties to be informed,
• Object to a result arising from the exclusive use of automated systems,
• Request compensation for damages caused by the unlawful processing of personal data.

To exercise your rights mentioned above, you can submit your request in writing or through your registered email address, secure electronic signature, mobile signature, or other electronic means previously notified to the COMPANY.

The application will only concern the person making the request, and information regarding other family members or third parties will not be provided. The COMPANY reserves the right to verify your identity before responding.

Your application must include:

I. Your name, surname, and signature (if in written form),
II. Your Turkish ID number or for foreign citizens, nationality, passport number, or ID number,
III. Your residential or workplace address for notification,
IV. If applicable, your electronic mail address, phone, and fax numbers,
V. The subject of your request,
and any related documents.

For written applications, you can send them to our address at:

Dereboyu Cd. Çalışkan Sk. No:4 Halkalı 34303 Küçükçekmece/İstanbul, Turkey.

For email applications, send them to kvkk@transvaro.com, or for KEP (secure electronic mail) applications, use transvaro@hs02.kep.tr.

To allow for proper identification, your application must include all necessary and accurate information. If the information is incomplete or inaccurate, there may be issues in processing your request, and the COMPANY reserves the right to take necessary legal actions.

GUARANTEE POLICY

All reservations must be guaranteed with a valid credit card at the time of booking.