Information Text on Camera Recordings within the Scope of Kvkk

TUĞCAN OTELCİLİK TURİZM ANONİM ŞİRKETİ carries out personal data processing activities at building facility entrances and within the facility in accordance with the Constitution of the Republic of Turkey, the Personal Data Protection Law (“PDPL”) and other relevant legislation. In order to ensure security as a data controller in accordance with the PDPL Law, TUĞCAN HOTEL carries out personal data processing activities in our Company’s buildings, factories and facilities with security camera monitoring activities and monitoring the entrances and exits of customers, guests, subcontractors, visitors and their vehicles.

CAMERA MONITORING AND RECORDING ACTIVITIES CARRIED OUT AT THE ENTRANCES AND INSIDE THE BUILDINGS AND FACILITIES

TUĞCAN HOTEL processes personal data by capturing images with a closed circuit camera system in the Company’s premises in order to ensure legal, technical and commercial occupational safety.

1.1. Legal Basis for Camera Monitoring Activity and Method of Collection of Personal Data

The camera monitoring and recording activity carried out by TUĞCAN HOTEL is carried out in accordance with the Private Security Services Law No. 5188 and the regulation on the implementation of this law and based on the legal reason based on the legitimate interest of our Company.

Personal data is collected in the electronic environment through closed circuit camera systems in order to ensure the security of the TUĞCAN HOTEL operator within the framework of the personal data processing conditions specified in Articles 5 and 6 of the PDP Law.

1.2. Conducting Security Camera Monitoring Activity According to the PDP Law

TUĞCAN HOTEL carries out security camera monitoring activities in order to ensure security in its facilities, for the purposes stipulated in the relevant legislation in force and in accordance with the personal data processing conditions listed in the PDP Law.

1.3. Announcement of Camera Monitoring Activity

TUĞCAN HOTEL informs the personal data owner in accordance with Article 10 of the PDP Law.

TUĞCAN HOTEL notifies about the camera monitoring activity of the general issues with more than one method. Thus, it is aimed to prevent harm to the fundamental rights and freedoms of the personal data owner, to ensure transparency and to enlighten the personal data owner.

In terms of the camera monitoring activity by TUĞCAN HOTEL; a notification letter stating that monitoring will be carried out is hung at the entrances of the areas where monitoring is carried out.

1.4. Purpose of Carrying Out the Camera Monitoring Activity and Limitation to the Purpose

TUĞCAN HOTEL processes personal data in a way that is related to the purpose for which they are processed, limited and measured in accordance with Article 4 of the Personal Data Protection Law.

The purpose of TUĞCAN HOTEL's closed circuit camera monitoring activity is limited to the purposes listed in this information text.

In this context, the monitoring areas, numbers of security cameras and when monitoring will be carried out are put into practice in a sufficient and limited manner to achieve the security purpose.

The privacy of the person is not subject to monitoring in areas that may result in interventions that exceed security purposes (for example, mosques, toilets, etc.).

1.5. Ensuring the Security of the Obtained Data

TUĞCAN HOTEL takes the necessary technical and administrative measures to ensure the security of personal data obtained as a result of camera monitoring activities in accordance with Article 12 of the Personal Data Protection Law.

1.6. Storage Period of Personal Data Obtained through Camera Monitoring Activities

TUĞCAN HOTEL stores personal data obtained through cameras for 60 days.

1.7. For What Purposes and to Whom Will the Obtained Personal Data Be Transferred

A limited number of employees have access to the information obtained as a result of monitoring. Camera images can be transferred to authorized public institutions in accordance with the legislation in order to ensure the security of our company within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Personal Data Protection Law. (For example, upon the written request of the prosecutor's office or judge during the investigation of an incident) As a result of the confidentiality agreement made between a limited number of people who have access to the records and our company, the people declare that they will protect the confidentiality of the data they access.

MONITORING THE ENTRANCES AND EXITS OF GUESTS AND SUBCONTRACTORS AT AND WITHIN THE FACILITY ENTRANCES

TUĞCAN HOTEL; As the data controller in accordance with the Personal Data Protection Law, personal data processing activities are carried out to ensure security and to monitor the entrances and exits of guests in TUĞCAN HOTEL facilities for the purposes specified in this disclosure text.

While the names and surnames of the people who come to TUĞCAN HOTEL buildings as guests are obtained or through texts hung at TUĞCAN HOTEL or made accessible to the guests in other ways, the owners of the personal data in question are informed within this scope. Customer 

The data obtained for the purpose of tracking entry and exit is processed only for this purpose and the relevant personal data is collected in a physical environment during the visit of the TUĞCAN HOTEL building, based on the legal reason related to the legitimate interest of our Company, within the framework of the personal data processing conditions specified in Articles 5 and 6 of the Personal Data Protection Law, and is recorded in the data recording system.

The personal data collected within the scope of visiting the TUĞCAN HOTEL buildings can be transferred to authorized public institutions in accordance with the legislation in order to ensure the security of the TUĞCAN HOTEL buildings, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Personal Data Protection Law.

PURPOSES OF PROCESSING, CATEGORIZATION AND STORAGE PERIOD OF PROCESSED PERSONAL DATA

TUĞCAN HOTEL informs the personal data owner about which personal data groups it processes within the scope of the obligation to inform in accordance with Article 10 of the Personal Data Protection Law, the purposes of processing the personal data of the personal data owner and the storage periods.

DELETION, DESTRUCTION AND ANONYMIZATION OF PERSONAL DATA

TUĞCAN HOTEL has processed the personal data mentioned in this disclosure text in accordance with the relevant provisions of the law as regulated in Article 138 of the Turkish Penal Code and Article 7 of the Personal Data Protection Law, but if the reasons requiring processing are eliminated, personal data is deleted, destroyed or anonymized based on TUĞCAN HOTEL's own decision or upon the request of the personal data owner.

RIGHTS OF PERSONAL DATA OWNERS AS STATED IN ARTICLE 11 OF THE PDPL

We hereby inform you that personal data owners have the following rights in accordance with Article 11 of the PDPL:

To learn whether their personal data has been processed,
To request information regarding their personal data if they have been processed,
To learn the purpose of processing their personal data and whether they are used in accordance with their purpose,
To know the third parties to whom their personal data has been transferred domestically or abroad,
To request correction of their personal data if they have been processed incompletely or incorrectly and to request notification of the transaction made within this scope to the third parties to whom their personal data has been transferred,
To request deletion or destruction of their personal data if the reasons requiring processing are eliminated, despite the fact that they have been processed in accordance with the provisions of the Law and other relevant laws, and to request notification of the transactions made within this scope and in cases where their personal data has been processed incompletely or incorrectly to the third parties to whom their personal data has been transferred,
To have their processed data analyzed exclusively through automated systems object to a result that is against you,

Request compensation for damages in case of damages due to unlawful processing of your personal data.
You can submit your applications regarding your rights listed above to our Company by filling out the Application Form that you can access through our general information text at www.tugcanhotel.com.tr. 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 a fee according to the tariff to be determined by the Personal Data Protection Board.

Tuğcan Hotel