MP HOTELS  PRIVACY POLICY

Data Controller: MP Hotel Management Turizm İnşaat Yatırım Ticaret Anonim Şirketi

Mersis No: 0859050628000014

Address: Çağlayan Mah. 2054 Sk. Yaren Turizm Ltd. Şti. Sitesi No: 8 Muratpaşa / Antalya

Phone Number:

E-mail: kvkk@mphotels.com.tr

 

Dear Guest;

 

This Privacy Notice, prepared within the scope of the protection of personal data, constitutes our general privacy notice under the Law No. 6698 on the Protection of Personal Data, as implemented throughout our hotel.

Hereinafter, our hotel and company shall be referred to as “MP Hotels” or “Hotel.”

 

As MPHM Hotels, we attach the utmost importance to the protection of your personal data. In this context, we process your personal data, in our capacity as the “Data Controller” under the  Personal Data Protection Law numbered 6698 (“PDPL”), within the scope of the purposes and legal limits set out below, and we take care to fully implement the necessary administrative and technical security measures throughout this process. Through this “Privacy Notice” prepared accordingly, we aim to provide our valued guests and visitors with information regarding the processes related to the processing of personal data and to inform them of their rights under the PDPL and the GDPR.

 

1.Personal Data We Process

 

Within MPHM Hotels, the following personal data relating to our guests staying at our hotel, and, to the extent necessary, their family members/visitors, may be processed:

  • Identity Information: Full name, Turkish ID number, passport number, nationality, date of birth, etc.
  • Contact Information: Telephone number, e-mail address, residence/address information, etc.
  • Accommodation Information: Check-in and check-out dates, room number, length of stay, reservation details, agency information, etc.
  • Financial Information: Information relating to payment and invoicing processes, and credit card details (solely for payment processing and reservation security purposes and in accordance with the applicable legislation).
  • Information Relating to Child Guests: Only to the extent necessary, name, date of birth, and nationality information, and, where required, a letter of consent.
  • Special Categories of Personal Data (Where Explicit Consent Is Provided): Health status, disability status, special room requirements, allergy information, etc., for the purposes of personalizing the service and ensuring guest satisfaction.
  • Preference and Service Usage Information: Room preferences, smoking/non-smoking room preference, service requests, and requests and satisfaction feedback communicated during the stay.
  • Security and Facility Protection Data: Image recordings obtained through closed-circuit camera systems (CCTV) located in the common areas of the hotel, retained solely for the purpose of ensuring security and in accordance with the applicable legislation.
  • Use of Photographs and Visual Materials (Where Explicit Consent Is Provided): The use of photographs and video recordings taken during the stay in which the individual appears, on social media, the website, or in press/media outlets, may only be carried out within the scope of the guest’s explicit consent given of their own free will.

Personal data collected in relation to guests under the age of 18 is limited solely to the data necessary for identification and the provision of accommodation services, and such data may only be provided by their parent or legal guardian.

 

2.Time and Method of Collection of Your Personal Data

Your personal data may be collected by MPHM Hotels during your use of the services provided by us and in connection with your accommodation processes, through verbal, written, or electronic means, by fully or partially automated methods or by non-automated methods provided that they form part of a data recording system. In this context, your personal data may be collected through the circumstances and channels set out below:

2.1. Data Collected Within the Scope of Hotel Services

  • Check-in, accommodation, and check-out procedures,
  • Payment, invoicing, and security deposit procedures,
  • Use of the hotel restaurant, bar, and other facility services,
  • Requests, complaints, and satisfaction feedback  submitted as part of guest relations,
  • Reservation and service processes relating to weddings, meetings, events, and similar organizations,
  • Completion of suggestion, evaluation, and satisfaction surveys.

2.2. Data Transferred from Third-Party Sources

  • Information transmitted to our property as a result of reservation transactions made through travel agencies, tour operators, online reservation platforms, GDS systems, and similar third-party channels.

2.3. Data Collected Through Digital and Online Channels

  • Transactions carried out through the MPHM Hotels websites and online reservation systems (including IP information, cookie data, and online transaction records),
  • Information shared through online forms, surveys, and our social media accounts.
  • Personal data obtained through these processes is processed, retained, and protected in accordance with the legal grounds set out under PDPL and in compliance with the applicable legislation.

 

3.Legal Grounds for the Processing of Your Personal Data

In this context, your personal data obtained may be processed pursuant to Article 5 of the PDPL for the purposes set out in Article 3 of this Notice, within the scope of the performance of the accommodation and facility services provided at our Hotel, the fulfilment of the legal obligations arising from the legislation to which the Hotel is subject, the ensuring of facility security, and the legitimate interests relating to the conduct of guest relations processes. Pursuant to Article 6, special categories of personal data may be processed where your explicit consent has been obtained.

Your personal data may be collected through the following methods and channels:

  • By hand during applications made in person,
  • Through the Hotel’s websites,
  • Via e-mail, post, or similar communication channels,
  • Through the Hotel’s business partners, suppliers, travel agencies, tour operators, and online reservation platforms,
  • Through social media platforms and other digital communication channels,
  • Through information shared during face-to-face meetings, telephone calls, teleconferences, video calls, fax communications, and similar means of communication.

The legal grounds set out under PDPL are as follows:

  1. Your explicit consent,
  2. Where expressly provided for by law,
  3. Where it is necessary for the protection of the life or physical integrity of the person who is unable to express consent due to actual impossibility, or whose consent is not legally valid, or of another person,
  4. Where it is directly related to the establishment or performance of a contract,
  5. Where it is necessary for the data controller to fulfil its legal obligations,
  6. Where the personal data has been made public by the data subject,
  7. Where data processing is necessary for the establishment, exercise, or protection of a right,

      8.  Where data processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

 

4. Purposes for Processing Your Personal Data

Your personal data is processed within the scope of the personal data processing conditions set out in Articles 5 and 6 of PDPL, for the purposes of enabling you to benefit from the accommodation and facility services provided by our hotel, carrying out guest relations processes, ensuring facility security, and fulfilling our legal obligations.

In this context, your data is used for purposes such as carrying out reservation, check-in and check-out procedures, payment and invoicing processes, planning and providing services, evaluating requests and complaints, conducting customer satisfaction activities, and managing guest relations. In addition, your personal data may also be processed for the purposes of ensuring facility security, fulfilling identity notification obligations, conducting legal processes, and making the records and notifications required under the applicable legislation.

Provided that your explicit consent has been obtained, your personal data may also be used for purposes such as personalizing services, carrying out marketing and information activities, sending campaigns and announcements, and conducting surveys and satisfaction assessments.

All such processing activities are carried out solely for the purposes specified above and in compliance with the applicable legislation.

 

5. Domestic and International Transfer of Your Personal Data

Your personal data may be transferred and/or made accessible, in a controlled and limited manner, subject to the necessary security measures and under the supervision of the Hotel’s technical units, to entities located in Türkiye and abroad that provide storage, archiving, and information technology support services (such as server, hosting, and cloud computing services); to financial institutions; to consultancy firms from which legal and similar support services are obtained; to third parties providing support in other areas related to the Hotel’s activities; and, for the specified purposes, to our business partners and competent public authorities and institutions.

 

During the domestic transfer of your data, our Hotel fulfils all obligations arising under PDPL and the applicable legislation. Within the scope of legal obligations and where necessary, your personal data may also be transferred to public institutions, judicial authorities, and foreign missions established under international treaties (such as embassies and consulates).

 

6. Retention Period for Your Personal Data

Your personal data will be processed until the end of the retention period prescribed under the applicable legislation, if such a period is stipulated for the retention of such data; if no such period has been specified, it will be processed for the period necessary for the purpose for which it is processed. Upon the expiry of such periods, your personal data will be deleted, destroyed, or anonymized ex officio or upon your request, without delay and in accordance with the applicable legal provisions.

 

7. Monitoring of Hotel Premises by Camera

For the purposes of ensuring facility security, safeguarding the security of our guests and employees, conducting occupational health and safety processes, and serving as evidence in the event of possible legal disputes, MPHM Hotels carries out camera recording at facility entrances and exits, corridors, common areas, and exterior façades. Such personal data is processed pursuant to Article 5/2(f) of the PDPL, based on the legal ground of the legitimate interests of the data controller. Camera recordings are accessible only by authorized units and are retained in compliance with the applicable legislation and subject to appropriate security measures. The recordings are stored for the period required by the purpose of processing and are subsequently destroyed. Camera recordings may be shared with competent public institutions and authorities upon request. To exercise your rights regarding your personal data within the scope of Article 11 of the PDPL, you may submit your request to our Company via kvkk@mphotels.com.tr

 

  1. Your Rights as a Data Subject under PDPL (Article 11)

Pursuant to Article 11 of the PDPL, by applying to our Company, you have the right to:

  1. Learn whether your personal data is being processed,
  2. Request information if your personal data has been processed,
  3. Learn the purpose of the processing of your personal data and whether it is used in accordance with that purpose,
  4. Know the third parties to whom your personal data has been transferred, whether domestically or abroad,
  5. Request the correction of your personal data if it has been processed incompletely or inaccurately,
  6. Request the deletion or destruction of your personal data within the framework of the conditions set out in the relevant provisions of the Law,
  7. Request that the transactions carried out pursuant to subparagraphs (e) and (f) be notified to third parties to whom your personal data has been transferred,
  8. Object to the emergence of a result against you through the analysis of your processed data exclusively by automated systems,
  9. Request compensation for the damage in the event that you suffer damage due to the unlawful processing of your personal data.
  10. You have these rights.

 

To exercise your rights set out above, you may submit a signed written request containing the information necessary to verify your identity, together with your explanations regarding the right you wish to exercise under Article 11 of PDPL, by delivering it in person, along with documents identifying your identity, to Çağlayan, 2054 Sk. No: 8, 07230 Muratpaşa/Antalya – Türkiye; by applying in person at our company and completing our request form; by sending it through a notary public or by other methods specified under the PDPL; or by sending the relevant application, signed with a secure electronic signature, to kvkk@mphotels.com.tr