Lusso Hotel

PERSONAL DATA PROTECTION LAW

Fox Bau Yapı Kimyasalları Anonim Şirketi regards the protection of fundamental rights and freedoms above all, together with the protection of privacy, the provision and maintenance of information security and respect for ethical values, as among its primary principles. In order to fulfil the disclosure obligation arising from Article 10 of the Personal Data Protection Law, our company, which holds the title of Data Controller under Law No. 6698 on the Protection of Personal Data (KVKK), submits for your information the following explanations concerning the processing and protection of your personal data and your special categories of personal data. The term personal data used in this document is used so as to cover special categories of personal data as well.

If you do not accept this policy, you should not send us your personal data. However, we would like to point out that in that case there may be disruptions in the services we provide to you and that the service offered may not be fully functional.

We note that you are responsible for the accuracy and currency of the personal data you send us; and if you share the personal data of other people with us, it will be understood that you have obtained from the third party concerned all the permissions required for us to collect, process, use and disclose the information belonging to them, and our Company cannot be held liable in this respect.

OUR PRINCIPLES FOR PROCESSING PERSONAL DATA

All personal data processed by our Company is processed only in accordance with the procedures and principles laid down in the Law and in other laws. Pursuant to Article 4 of the KVKK, the basic principles we observe when processing your personal data are as follows:

Being processed lawfully and in accordance with the rules of good faith.
Being accurate and, where necessary, up to date.
Being processed for specific, explicit and legitimate purposes.
Being relevant, limited and proportionate to the purposes for which they are processed.
Being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

CATEGORIES OF DATA SUBJECTS

A separate policy applies to the processing of the personal data of our employees (including interns and subcontractor employees) whose personal data are processed by our Company. Data subjects other than employees, such as customers, potential customers, visitors, job candidates/interns and the employees, shareholders and officers of the institutions we cooperate with, may also address their requests to our Company under the KVKK.

PURPOSE OF PROCESSING AND TRANSFERRING PERSONAL DATA

Our Company processes personal data only for the purposes and under the conditions set out in the personal data processing conditions specified in Article 5, paragraph 2 and Article 6, paragraph 3 of Law No. 6698 on the Protection of Personal Data. Personal data may be processed where at least one of the items listed below is present:

The existence of the explicit consent of the data subject,
Being expressly provided for by law,
Being necessary for the protection of the life or physical integrity of the person himself or herself or of another person, where that person is unable to give consent due to actual impossibility or whose consent is not deemed legally valid,
Being necessary to process the personal data of the parties to a contract, provided that it is directly related to the conclusion or performance of that contract,
Being mandatory for the data controller to fulfil its legal obligation,
Having been made public by the data subject,
Being mandatory for the establishment, exercise or protection of a right,
Being mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Under the conditions stated above, our Company may process personal data for the following purposes:

Evaluating potential suppliers/business partners,
Establishing and managing customer relations,
Conducting and concluding the contract process with our suppliers/business partners,
Conducting direct marketing processes,
Communication and support (upon your request),
Compliance with legal obligations,
Protecting the interests of the Company and ensuring its security,
Planning and carrying out the Company's commercial activities,
Reporting and auditing,
Protection of rights and interests.

We share your Personal Data with other parties, including professional advisers such as those listed below:

We share your personal data and your special categories of personal data, within the framework of legal grounds and your consent and within the scope of the personal data processing purposes stated above, with public institutions and organisations, banks, insurance companies, auditors, lawyers, accountants, other external professional advisers, the Joint Health and Safety Unit for the purpose of fulfilling occupational health and safety obligations, law enforcement authorities in line with our legal obligations, domestic and foreign service providers from which we receive services within the scope of marketing activities where consent has been given, and our contracted workplace physician.

WHEN DO WE COLLECT PERSONAL DATA ABOUT YOU?

We collect your personal data in the following cases:

When you visit our Company, or purchase or use our products and services,
If you are a natural or legal person purchasing goods and services from our Company,
When you sell us goods or provide us with services,
When you choose to receive our marketing communications,
When you contact us through our website, e-mail, social media platforms, other online channels or by telephone,
When you take part in our company events, social responsibility projects and organisations,
When you contact us for any purpose as a potential customer, supplier, business partner or subcontractor,
If you have applied for a job with our Company in any way or have made your CV and related information available for our Company's review.

We will process the personal data we obtain in the above cases only in accordance with this Notice.

WHICH OF YOUR PERSONAL DATA DO WE PROCESS?

Our personal data processing methods operate through our website, by telephone or e-mail, through electronic applications specific to our customers, through your participation in our business events and surveys, or through your interaction with us in any other way. In this context, the categories of personal data we process about you are as follows:

Identity information
Contact information
Images and/or videos that may identify you
Financial data
Any other information you decide to share with our Company of your own accord
Automatically collected electronic data
Legal transaction and compliance information
Corporate customer/Supplier data
Incident management and security information
Personal data collected from other sources

ON WHICH LEGAL GROUNDS DO WE PROCESS YOUR PERSONAL DATA?

Personal data is collected, used, recorded, stored and processed by our Company by providing data subjects with clear and comprehensible written information and, where necessary, obtaining their explicit consent, lawfully and in accordance with the rules of good faith, in a manner connected with and limited to the legitimate purpose clearly stated above, and within the framework of the principle of proportionality.

We process your personal data in line with the following legal grounds, which are set out in Article 5 of the KVKK and also appear under the heading "Purpose of Processing and Transferring Personal Data" of this policy, in particular the Turkish Commercial Code No. 6102, the Turkish Code of Obligations No. 6098, the Tax Procedure Law No. 213 and electronic commerce legislation:

The existence of the explicit consent of the data subject,
Being expressly provided for by law,
Being necessary for the protection of the life or physical integrity of the person himself or herself or of another person, where that person is unable to give consent due to actual impossibility or whose consent is not deemed legally valid,
Being necessary to process the personal data of the parties to a contract, provided that it is directly related to the conclusion or performance of that contract,
Being mandatory for the data controller to fulfil its legal obligation,
Having been made public by the data subject,
Being mandatory for the establishment, exercise or protection of a right,
Being mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Where your Personal Data is processed on the basis of explicit consent, we would like to point out that if you withdraw your explicit consent, you will be removed from the commercial membership programme for which the processing based on that explicit consent is necessary, and that as of the relevant date you will no longer be able to benefit from the advantages you enjoyed through such processing.

RETENTION AND DESTRUCTION PERIODS FOR PERSONAL DATA

Your personal data will be stored for the retention periods specified in the relevant legislation or for as long as the processing purposes mentioned above require. At the end of this period, the data will be deleted, destroyed or anonymised in full compliance with the KVKK. In this context, a Personal Data Retention and Destruction Policy and the related procedures have been prepared and are applied.

HOW DO WE PROTECT YOUR PERSONAL DATA?

In order to protect your personal data and to prevent unlawful access to it, our Company takes the necessary administrative and technical measures in line with the Personal Data Security Guide published by the Personal Data Protection Authority, draws up internal procedures, prepares disclosure and explicit consent texts and, pursuant to Article 12/3 of the KVKK, carries out, or has carried out through external services, the audits necessary to ensure the implementation of the provisions of the KVKK.

WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

Pursuant to Article 11 of the KVKK, everyone has the following rights concerning themselves by applying to the data controller:

To learn whether personal data is processed,
To request information if personal data has been processed,
To learn the purpose of processing personal data and whether it is used in accordance with that purpose,
To know the third parties to whom personal data is transferred in Turkey or abroad,
To request the correction of personal data if it has been processed incompletely or incorrectly,
To request the deletion or destruction of personal data within the framework of the conditions set out in Article 7 of the KVKK,
To request that the operations carried out pursuant to subparagraphs (d) and (e) be notified to the third parties to whom the personal data has been transferred,
To object to a result arising against the person themselves through the analysis of the processed data exclusively by automated systems,
To request compensation for the damage suffered in the event of damage due to the unlawful processing of personal data.

TO MAKE A REQUEST UNDER THE PERSONAL DATA PROTECTION LAW

To obtain more detailed information about your Personal Data, you can access the information request application form from our company's website at https://www.foxbau.com/ and from the address Organize Sanayi Bölgesi 1. Kısım 7. Cadde No:6 Döşemealtı – Antalya / TÜRKİYE in person.

So that we can respond to your requests regarding your Personal Data as quickly as possible, your requests and questions must be submitted clearly, comprehensibly and with a specific date.

COOKIE POLICY

1. INTRODUCTION

1.1. Purpose

Fox Bau Yapı Kimyasalları Anonim Şirketi, we collect your personal data through “cookies” for a number of different purposes whenever you visit our websites, our mobile sites or our mobile applications.

In this policy we explain what cookies are, how we use them, the different types of cookie we use and how you can change or delete them.

We hope this policy gives you clear information about our use of cookies and also helps you feel secure. If you have further questions on this subject, please do not hesitate to contact us.

This Cookie Policy may be amended at any time for revision purposes. To see when this Cookie Policy was last revised, you can look at the “REVISION TABLE” section at the top of this page. Any change to this Cookie Policy takes effect once we make the policy available on our site or through the site.

For more detailed information about the personal data collected through cookies, you can review our Personal Data Protection and Privacy Policy.

1.2. What Is a Cookie?

A cookie is information stored on your computer by a website you visit. Cookies are generally used to store your settings for that website, such as your language preference or your location. Cookies may also contain many different kinds of information, including your personal information (your name, e-mail address, telephone number, etc.). However, the information a site can reach is limited to what you provide to it. Websites cannot access information you have not given them. Nor can any site reach the other files on your computer.

1.3. Our Purposes in Using Cookies

We use cookies to identify products/services that are useful for you, to count visits to a page, to improve the user experience, to design a more practical website interface for you and to provide personalised, relevant advertising services.

1.4. Types of Cookie

1.4.1. Essential Cookies

Essential cookies are required for access to our website, our mobile site and our mobile applications and for these to work as intended. They enable you to benefit from the related services. Without essential cookies, our website, our mobile site and our mobile applications cannot work smoothly for you and some of the services you request may not be provided.

Cookie Type	Purpose of Use
Session Cookies	Used to maintain the user's state within the system.
Load Balancing	Used so that the increasing traffic of the system can be distributed across servers in different locations.
User Identity	Used to recognise the user in the system and to present information specific to them.
Security	Used to verify both the system and the user.

1.4.2. Preference Cookies

Used to determine your usage preferences and behaviour (language option, geographical region information, etc.) and then, by remembering this information, to present a user interface customised for you.

Cookie Type	Purpose of Use
Language	Used to determine and store the language the user commonly uses and to adapt the interface accordingly.
Location	Used to obtain the approximate address (country, city, etc.) automatically from the IP address the user logs in from, in order to offer products/services specific to that region.
Mobile	Used to determine whether the user has logged in to the system from a mobile device, for design dimensions, system requirements and performance purposes.
Last visit and activity	The date of the last visit, activity and other information are recorded in order to understand the user's preferences by providing an update on "what has changed since your last visit".
Last watched video	Used to present different content on the user's next visit if they have watched a video offered within the system to introduce a product/service.
Instant cookies	Generally used to present interactive content (pop-up, video or audio) to the user immediately on first entry to the system.
Page History	Used so that a user moving between different pages within the system can quickly go forward, back or directly to a page they want; also so that they can be redirected to the previous page if they encounter a problem during page transitions. In addition, it is used for error reporting and resolution for the relevant page if a problem occurs on the page they are on.

1.4.3. Social Plug-in Tracking Cookies

These cookies are used for market research and product development by tracking social media users.

Cookie Type	Purpose of Use
Facebook	Enables Facebook members (or non-members) to be tracked for market analysis and product development purposes.
Twitter	Used to track people who are members of social media networks or not, for market analysis and product development purposes.

1.4.4. Analytics Cookies

Analytics cookies are collected in order to make the system more understandable and practical for users. These cookies are used so that the system can be adapted to users in general.

Cookie Type	Purpose of Use
Google Analytics	Used so that users' habits are better understood by the system as a result of user data being processed in aggregated form by Google as statistical data.

1.4.5. Marketing Cookies

This type of cookie is used within the scope of marketing activities.

Cookie Type	Purpose of Use
Advertising	Used to show behavioural and targeted advertisements to visitors.
Market Analysis	Used to carry out market analysis.
Campaign	Used to measure the impact of campaigns.
Fraud Detection	Used to detect click fraud.

1.5. Managing Cookies

Our websites, our mobile sites and our mobile applications are set by default to accept cookies automatically. If you want to remove existing cookies from your device, you can use your browser options. You can also block cookies through your browser settings if you do not want cookies to be placed on your device thereafter.

You should be aware that if you remove or block the cookies we use, there may be certain effects while using our website, our mobile site or our mobile applications and the site may not be fully functional. Unless you block cookies in your browser settings, our system will place cookies again when you visit our site or click a link in an e-mail sent to you by us, even if you have previously deleted our cookies.

1.6. To Contact Us

If you have further questions about our “Cookie Policy”, please contact us at info@foxbau.com or at Organize Sanayi Bölgesi 1.Kısım 7.Cadde No:6 Döşemealtı – Antalya / Türkiye.

Fox Bau Yapı Kimyasalları Anonim Şirketi

INFORMATION REQUEST APPLICATION FORM

As Fox Bau Yapı Kimyasalları Anonim Şirketi we count among our primary principles the protection of fundamental rights and freedoms above all, together with the protection of privacy in private life, the provision and protection of information security, and respect for ethical values. Article 11 of Law No. 6698 on the Protection of Personal Data, titled "Rights of the Data Subject", grants data subjects the right to make certain requests regarding the processing of their personal data. As the "Data Controller", our Company has prepared this information request application form in order to enable Data Subjects to exercise these rights and to fulfil the disclosure obligation set out in Article 10 of the KVKK.

Pursuant to Article 11 of the KVKK, you can exercise the following rights by applying to Fox Bau and completing the form attached:

You can learn whether your personal data is being processed,
If your personal data has been processed, you can request information about it,
You can learn the purpose of the processing of your personal data and whether it is used in accordance with that purpose,
You can learn the third parties, in Turkey or abroad, to whom your personal data has been transferred,
If your personal data has been processed incompletely or incorrectly, you can request that it be corrected,
You can request that your personal data be erased or destroyed within the conditions set out in Article 7 of the KVKK,
You can request that the operations carried out pursuant to sub-paragraphs (e) and (f) be notified to the third parties to whom the personal data has been transferred,
You can object to a result arising against you through the analysis of the processed data exclusively by automated systems,
If you suffer damage due to the processing of your personal data contrary to the KVKK, you can request that the damage be compensated.

Pursuant to Article 13 of the KVKK, in their applications to our Company data subjects must submit their requests in writing or by the other methods to be determined by the Personal Data Protection Board. In this context, applications to our Company can be submitted to us free of charge by printing out this form once completed and choosing one of the four methods below:

No.	Application Method	Address to Which the Application Will Be Made	Action Required
1	By the data subject applying in person by coming to our Company (the data subject must have documents establishing their identity with them)	Organize Sanayi Bölgesi 1.Kısım 7.Cadde No:6 Döşemealtı – Antalya / Türkiye	"Personal Data Protection Information Request" must be written on the envelope.
2	Notification through a notary public	Organize Sanayi Bölgesi 1.Kısım 7.Cadde No:6 Döşemealtı – Antalya / Türkiye	"Personal Data Protection Information Request" must be written on the notification envelope.
3	By Registered Electronic Mail (KEP), signed with a "Secure electronic signature" as defined in Electronic Signature Law No. 5070	info@foxbau.com (TODO - KONTROL: sartech@hs03.kep.tr)	The subject of the e-mail must be "Personal Data Protection Law Information Request".
4	By e-mail	info@foxbau.com	The subject of the e-mail must be "Personal Data Protection Law Information Request".

Third parties cannot exercise the right to obtain information regulated in Article 11 of the KVKK on behalf of data subjects. In order for a request to be made regarding the personal data of a person other than the data subject, the wet-signed and notarised original of a special power of attorney issued by the data subject in the name of the person who will make the application must be presented.

If the operation requested by the Data Subject requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board will be charged by our Company.

Pursuant to Article 13/2 of the KVKK, the applications submitted to us will be answered within thirty days from the date your request reaches our Company, depending on the nature of the request. Our responses will be delivered to you in writing or electronically pursuant to Article 13 of the KVKK.

Lusso Hotel

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