Clarification Text Regarding the Processing of Personal Data

As Öztanık Otelcilik Turizm ve Ticaret A.Ş. ("Öztanık Otelcilik"), we attach great importance and sensitivity to the confidentiality and security of your personal data. In this context, it is one of our priorities to process and store all kinds of personal data belonging to all persons associated with Öztanık Otelcilik, including our guests who benefit from our services and products and our contacts with whom we have a business relationship, in accordance with the Law No. 6698 on the Protection of Personal Data ("KVKK").

With the title of "Data Controller" we carry in accordance with the KVKK and with the awareness of this responsibility, we would like to inform you as follows about the purposes of processing your personal data, the methods and reasons for collecting your data, your rights regarding the processing of your personal data, and the application procedures and principles, which are the method of exercising these rights.

WHAT PERSONAL DATA DO WE COLLECT?

As Öztanık Otelcilik, we collect personal data belonging to our guests, visitors and business contacts (including shareholders, officials and employees of the institutions with which we have all kinds of business relations such as travel agencies, suppliers, subcontractors) in accordance with the KVKK when necessary. Personal data we collect we can list the data as follows:

• Identity Data: From our guests, visitors, business contacts (shareholders, officials and employees of the organizations with which we have all kinds of business relations such as travel agencies, suppliers, subcontractors)

The data we collect are data about the identity of the person such as name, surname, Turkish ID number, nationality, vehicle license plate information, photocopy of ID card.

• Contact Data: From our guests, visitors, business contacts (shareholders, officials and employees of the organizations with which we have all kinds of business relations such as travel agencies, suppliers, subcontractors)

The data we collect that enables contact with the person such as telephone number, address, e- mail address.

• Data of Family Members / Relatives: Data about the family members, relatives or persons accompanying you during your stay, which we collect from our guests in accordance with the relevant legislation and/or in order to protect the legal and other interests of our Company or the person concerned.

• Financial Data: Data such as wages, salary information, payment information, credit card information that we collect from our guests and business contacts according to the legal relationship established by our company with the data subject

• Personal Data: From the officials and employees of the institutions with which we have subcontractor and similar business relations

All kinds of personal data that are the basis for the formation of the personal rights of real persons who are in a working relationship with our Company that we collect.

• Physical Space Security Data: From our guests, visitors, business contacts (sub Personal data such as security and camera records taken from the officials and employees of the contractor and similar institutions with which we have a business relationship) at the entrance to the physical space and during their stay in the space.

• Visual / Audio/Visual Data: Personal data such as photographs, audio and video recordings that do not fall within the scope of physical space security information and that we collect from our guests, business contacts (shareholders, officials and employees of the institution with which we have all kinds of business relations such as subcontractors, subcontractors).

• Transaction Data: The reservation information we collect from our guests, regarding the stay or visit Personal data related to the transactions carried out by the guest such as records, product or service purchases, membership information, groups and events related to accommodation, guest preferences.

• Contact and Complaint Management Data: Personal data obtained from our guests, visitors, business contacts (shareholders, officers and employees of the organisations with which we have all kinds of business relations such as travel agencies, suppliers, subcontractors) and other third parties during the processes of receiving and evaluating all kinds of requests or complaints against our company.

• Special Categories of Personal Data: Data such as health data, association foundation membership, biometric data (audio and video recordings), blood type and criminal conviction information specified in Article 6 of the KVKK that we collect from our guests, visitors and business contacts.

• Other Data: From our guests, visitors, business contacts (shareholders, officials and employees of the organisations with which we have all kinds of business relations such as travel agencies, suppliers, subcontractors) and other data processed for technical transaction security that we collect from third parties, risk management information, legal transaction data, marketing data, location data, cookies and other means and data collected by automatic

WHAT METHODS AND LEGAL REASONS DO WE COLLECT/PROCESS YOUR PERSONAL DATA?

Your Personal Data,

-Through other means of communication, including printed and electronic forms, during booking, registration/entry to our facilities and during your stay in our facilities,

-Through our websites, social media accounts operated on behalf of Öztanık Otelcilik and its brands in various social media channels,

-Through e-mail, telephone, short messages ("SMS") or multimedia messages ("MMS"), other communication methods including printed and electronic forms that we use within the scope of Öztanık Otelcilik sales and marketing activities,

-By means of closed circuit camera systems in Öztanık Otelcilik head office and accommodation facilities,

-Through the applications in our accommodation facilities (sending messages over the television in the rooms, etc.);

-Through the Contracts we have signed with you or your authorised company within the scope of our business activities, commercial offers submitted, printed and electronic forms, documents, correspondence, applications made to us,

-Through business cards and other documents given by you within the scope of business meetings and events,

-Öztanık Otelcilik's group companies, business contacts, travel agencies or service/product suppliers.

We collect data through third parties such as companies; verbally, in writing or electronically, by various methods that are fully or partially automated or non-automated as part of any data recording system.

We process your personal data that we collect in line with the above methods based on one or more of the following legal reasons:

-Your explicit consent,

-The provisions of laws and regulations in force in the Republic of Turkey require processing,

-It is mandatory for the protection of your life or the life or bodily integrity of yourself or another person when you are unable to disclose your consent due to actual impossibility,

-It is necessary for the performance of the contract we have concluded with you or your company,

-If it is necessary to process your personal data in order to fulfil our legal obligations,

-If your personal data has been publicised by you,

-If it is necessary for the exercise or protection of our legal or contractual rights as a company,

-If the processing of your personal data is necessary for our legitimate interest, provided that it does not harm your fundamental rights and freedoms.

We keep all your personal data we process in accordance with the periods required by the KVKK and other legislation and in any case by taking all necessary administrative and technical measures as long as the above legitimate purposes do not disappear.

FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

We process your Personal Data we collect for the following purposes according to its nature:

• The performance of our hotel management activities, the realisation of your demands and expectations with the products and services offered to you by Öztanık Otelcilik, and the provision of the desired level of hospitality and personal experience to our guests,

• Carrying out the necessary planning, evaluation and studies by our business units to ensure that our guests benefit from our products and services;

• Communicating directly with our guests and business contacts in order to provide and manage services within the scope of our hospitality activities; providing correspondence, notifications and booking confirmations regarding our hospitality and accommodation services;

• Carrying out advertising and marketing activities for the products and services offered by Öztanık Otelcilik and informing about promotions, promotions, campaigns, offers, bulletins, events and similar issues conducting corporate communication activities, carrying out corporate communication activities, customizing and offering products and services according to the tastes, usage habits and needs of the relevant people;

• Conducting Marketing and Guest Relationship Management activities; managing loyalty programmes,

• Organising and informing about corporate communication and other events, campaigns and

invitations within this scope, conducting market research studies;

• In order to improve the digital platforms we offer to our guests and to provide an efficient and personalised experience to platform users, the number, type, frequency of visits, behaviour,

geographical location and similar statistics of users, to offer personalised content, campaigns and advertisements according to the interests and needs of platform users, and to use cookies for this purpose;

• Follow-up and evaluation of requests, suggestions and complaints received from relevant persons, guest satisfaction management and implementation of planning, statistics and satisfaction assessment studies in this context;

• Carrying out quality assessment and improvement studies in order to provide better and more reliable products and services and to ensure sustainability, and to carry out quality assessment and improvement studies with suppliers, subcontractors and similar business relations supervision of persons;

• Management of relations with business contacts, travel agencies, suppliers, subcontractors and similar companies in business relations, execution of business and commercial relations;

• Ensuring the legal and commercial security of persons who have a business relationship with Öztanık Otelcilik and Öztanık Otelcilik (Planning of administrative operations for the services provided by our Company, business partner/customer/supplier (authorized or employees) assessment and audit processes, legal compliance process, etc.);

• Ensuring the physical security and supervision of the facilities operated by Öztanık Otelcilik;

• Planning and execution of occupational health and safety processes;

• Exercise of legal rights, use of information on the transaction history after the termination of the legal relationship as evidence in case of dispute;

• Determination and implementation of commercial, legal and business strategies;

• Execution of policies related to financial affairs; e-invoice management;

• Planning, auditing and execution of information security processes, management of information technology infrastructure;

• Planning, reporting, visitor/customer statistics and similar analyses within the scope of our

company's activities and/or

• Ensuring compliance with domestic legislation, providing information requested by public

institutions and organizations, fulfilling reporting obligations.

DO WE TRANSFER YOUR PERSONAL DATA TO THIRD PARTIES AND/OR ABROAD?

In the presence of the above-mentioned legal reasons and in line with the stated purposes; In order to continue our Company's activities and business processes, we may transfer your personal data to our group companies located at home and / or abroad, our business partners providing services to our Company, our business partners providing services to our Company, our agencies we cooperate with and our business contacts providing online hotel reservation services, our suppliers, our third party service providers providing on-site services, our insurance companies, banks and financial institutions, our consultancy firms that we receive

support in similar fields such as law, tax, etc., our Company officials, shareholders, legally authorized public institutions and private persons, domestic and / or foreign storage, archiving, information technology support (server, tax, etc.) that process personal data on behalf of our Company. We may transfer your personal data to our consultancy firms, Company officials, shareholders, legally authorised public institutions and private persons, domestic and/or foreign service providers that process personal data on behalf of our Company in the fields of storage, archiving, information technology support (server, hosting, software, cloud computing, etc.), provided that they comply with the provisions regulated under the KVKK. As Öztanık Otelcilik, we undertake that your personal data will be kept securely and will not be processed unlawfully.

THE RIGHTS OF THE PERSONAL DATA OWNER WITHIN THE SCOPE OF KVKK AND APPLICATION PROCEDURES AND PRINCIPLES

i.  Your Rights Regarding Your Personal Data

We would like to state that you have the following rights regarding your data being processed within the Company:

• To learn whether your personal data is being processed,

• To obtain information about your personal data if they are being processed,

• To learn what the purpose of processing your personal data is and whether your personal data is used in accordance with its purpose,

• To learn who are the third parties to whom the data are transferred at home or abroad, if any,

and which data are transferred,

• To request correction of the processed personal data in case of incomplete or inaccurate personal data,

• In case of correction, deletion or destruction of your personal data, to request notification of these transactions to third parties to whom your personal data has been transferred,

• In the event that the reasons requiring the processing of your personal data disappear or your personal data

To request the deletion or destruction of your processed personal data if it becomes outdated,

• Object to the occurrence of a result to your detriment by analysing your processed personal

data exclusively through automated systems,

• You have the right to demand compensation for damages in case you suffer damage due to unlawful processing of your personal data.

ii. Application

You may submit your requests regarding your above-mentioned rights by filling out the application form below in writing or by registered e-mail address, secure electronic signature, mobile signature or to us before. You can send it to our Company via your e-mail address that you have notified and registered in our system. Please click here for the application form.

Öztanık Otelcilik shall respond to the requests addressed to it as soon as possible and within thirty days at the latest, depending on the nature of the request will be finalised free of charge within this period. In case a cost arises due to the fulfilment of your requests, we may only charge you the fees in the tariff determined by the Personal Data Protection Board.

We may accept the requests addressed to Öztanık Otelcilik or reject them by explaining the reason and we may communicate this answer in writing or electronically to the person making the request. If the request is accepted, Öztanık Otelcilik is obliged to fulfil the requirements of the request immediately.

iii.  Complaint

In the event that your requests addressed to Öztanık Otelcilik are rejected by the Company, if you are not satisfied with the answer given by the Company or if no answer is given, from the date the answer is notified to you.

You may file a complaint to the Personal Data Protection Board within 30 days from the end of the 30- day period and within 30 days from the end of the 30-day period if no response is given.

DATA CONTROLLER IDENTITY AND CONTACT DETAILS

This disclosure text has been issued by Öztanık Otelcilik AŞ., which is established in Turkey and whose information is given below, addressed to the relevant data subjects in the capacity of "Data Controller".

Trade Title  : ÖZTANIK OTELCİLİK VE TURİZM TİCARET ANONİM ŞİRKETİ

Address          : Kocatepe Mah.Topçu Cad.No:10 Taksim-Beyoğlu/İstanbul

Mersis No         0706003112500016

Telephone      : +902122544906

KEP address : [email protected]

This clarification text; ÖZTANIK OTELCİLİK VE TURİZM TİCARET ANONİM ŞİRKETİ ("Öztanık Otelcilik") and all our hotels (Golden Hotel Istanbul, Golden Age Hotel Bodrum, Crystal Hotel Bodrum, Golden Houses Bodrum) operating under the roof of Öztanık Otelcilik.