Cookie Policy

1. Purpose and Scope

Purpose and Scope The Personal Data Usage and Privacy Policy applies to all websites, desktop, and mobile applications operated by Bematur. Its primary purpose is to provide detailed explanations regarding the lawful personal data processing activities carried out by the Company and the principles adopted for the protection of personal data, thereby ensuring transparency by informing users about the data policy within this scope.

The Personal Data Protection and Privacy Policy has been created to inform individuals whose data is processed by Bematur, including but not limited to our employees, employee candidates, interns, intern candidates, online visitors, customers, and potential customers. Our policy is applied to all personal data processing activities within Bematur and has been prepared in consideration of the PDPL (Personal Data Protection Law), other legislation related to personal data, and standards in this field.

Through this information text, we provide details regarding our practices related to the processing of your personal data through all our digital assets (websites, desktop, and mobile applications) used by Bematur, the purposes for which your data is collected, how it is used, how this information can be modified, your rights under the Personal Data Protection Law, and how you may contact us when needed. Your use of this website shall mean that you have read and accepted the privacy practices outlined in this text.

The Personal Data Protection and Privacy Policy is subject to change. Therefore, visitors are advised to review this text periodically. Bematur reserves the right to make changes, corrections, updates, additions, deletions, or any other modifications to this Personal Data Protection and Privacy Policy at any time, with or without providing a reason. All changes will be announced here, and unless otherwise specified to you, any changes disclosed here shall take effect immediately.

 

2. Definitions

KVKK: Law No. 6698 on the Protection of Personal Data
Company: Bematur
Personal Data: Any information relating to an identified or identifiable natural person
Data Controller: The person who determines the purposes and means of processing personal data and manages the place where the data is systematically kept (data recording system)
Data Processor: A natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller
Processing of Personal Data: Any operation performed on personal data, whether fully or partially automated, or non-automated provided that it forms part of a data recording system, such as obtaining, recording, storing, retaining, altering, reorganizing, disclosing, transferring, acquiring, making available, classifying, or preventing its use
Anonymization of Personal Data: Making personal data impossible to associate with an identified or identifiable natural person under any circumstances, even by matching it with other data
Explicit Consent: Consent that is based on information regarding a specific subject and expressed with free will.

3. Protection of Personal Data

Pursuant to the Law No. 6698 on the Protection of Personal Data (“KVKK”), any information that enables the identification of a real person or makes a person identifiable is considered personal data (for example, your real name, address, phone number, email address, and user IP address). If the use of communication forms is necessary, we may ask you for specific personally identifiable information. We may also request your demographic information, interests, or similar data. Providing information about yourself is optional, and you may choose not to provide certain information. However, in such cases, you may not be able to use communication channels through the website or application.

In addition, non-personal identification information is automatically obtained when your computer communicates with our servers, including your usage information and the IP address recorded by our server.

At Bematur, personal data may be processed for the reasons, purposes, and methods described below, in compliance with the relevant legal regulations and the obligations for information retention, reporting, and disclosure imposed by legal authorities. This processing may be carried out by our company or by domestic or international entities affiliated with or cooperating with our company, and may involve data stored on servers located domestically or abroad; recorded in our systems; stored, retained, or preserved; classified for legal or financial purposes; updated; and, where permitted by law, disclosed or transferred to third parties.

If processing occurs abroad, it will be conducted in accordance with the applicable legislation of that country and under the prescribed security measures. We kindly ask you to review the legal provisions outlined below.

4. Purpose of Processing Personal Data

According to the Law, personal data is defined as any information relating to an identified or identifiable natural person, and any data falling within this scope is evaluated by Bematur in compliance with the relevant legislation. In this context, personal data is processed for purposes such as the provision of Bematur services and the execution of necessary operations in this regard, contacting you about our services with your explicit consent, conducting marketing activities, acquiring customers and sharing offers related to our services, as well as carrying out necessary reporting, customer statistics, and similar analyses within the scope of company activities.

 

5. Collection of Personal Data and Legal Basis

Personal data is collected from all kinds of verbal, written, or electronic sources, including but not limited to websites, customer communications, and designs, in order to be processed, transferred, and stored for the purposes stated above.

As the data controller, Bematur collects personal data, including sensitive personal data, through verbal, written, or electronic means based on explicit consent and within the framework of legal grounds arising from relevant legislation, contracts, requests, and principles of good faith. This is carried out in accordance with the obligations arising from KVKK and other applicable legislation, and for the purpose of providing quality services, conducting business and commercial activities via our corporate website, collaboration partners, employees, and social media platforms.

Within this scope, your personal data may be collected in written or electronic form by natural or legal persons processing data on behalf of Bematur, including but not limited to the following methods:

  1. Using browser cookies,
     

  2. Using mobile and desktop browser notifications,
     

  3. Using Google Analytics service,
     

  4. Using Google AdSense,
     

  5. Contact forms filled out on our websites or on third-party websites to get in touch with us,
     

  6. Contracts signed with our company and emails sent to our company,
     

  7. Information provided to our employees,
     

  8. Use of social media channels, Google, and other search engines.

6. Operations Related to the Processing of Personal Data

Sensitive personal data is processed by us in accordance with the measures prescribed by law and the administrative and technical precautions determined by the Personal Data Protection Board (KVK), provided that explicit consent exists or in cases required by legislation.

As Bematur, we process your personal data for the following purposes:

  • To conduct our business activities,
     

  • To provide support services within the scope of contracts and service standards,
     

  • To identify the preferences and needs of our online visitors and to shape and update the services we provide accordingly,
     

  • To ensure compliance with our legal obligations as required or mandated by applicable laws,
     

  • To conduct market research and statistical studies,
     

  • To maintain communication with individuals in a business relationship with the company,
     

  • For marketing purposes,
     

  • To perform legal reporting,
     

  • For invoicing,
     

  • To manage corporate communication,
     

  • To send newsletters or notifications via email.
     

7. Transfer of Processed Personal Data

For the purposes described above, Bematur may share personal data with the following parties:

  • Relevant departments providing services to continue company activities and business processes,
     

  • Domestic and/or international service providers processing personal data on behalf of the company,
     

  • When necessary, with official authorities, supplier companies, public institutions, business partners, and insurance companies.
     

Personal data will not be transferred to any parties that are incompatible with the company’s activities or purposes without the explicit consent of the data subject.

8. Security of Personal Data and Sharing with Third Parties

When you share your information with us within the scope of Personal Data Information at Bematur, all personal data provided to us will be kept confidential in Bematur’s database in accordance with Law No. 6698 on the Protection of Personal Data (KVKK). The information you provide to us will not be shared with third parties for any purposes other than those stated in this information text.

Bematur will not share your personally identifiable information with third parties for direct marketing purposes unless you have given explicit consent. If you choose to receive communications from a third party, your information will be subject to the privacy policy of that third party, not this privacy policy. Therefore, if you later do not want a third party to use your information, you must contact that third party directly.

Additionally, Bematur may share your personally identifiable information with third parties under the following circumstances:

  • Security of Bematur

Bematur has the right to disclose user information, including personally identifiable information, when legally required, upon the request of an official authority conducting an investigation, or to confirm and enforce compliance with Bematur’s administrative policies and applicable laws. Bematur also reserves the right to disclose such user information whenever it deems necessary to limit legal obligations or to protect or enforce the rights, interests, or safety of our users or others.

  • Corporate Changes

In the event of a corporate merger, acquisition, consolidation, sale of all assets, or any other type of corporate change, Bematur reserves the right to disclose, share, and/or otherwise transfer user information, including personally identifiable information.

  • Transfer of the Website

In a “Corporate Change,” without limitation to the rights reserved above, Bematur is authorized to transfer the information it has collected, including personally identifiable information, to any third party that assumes control over the services, acquires them, or otherwise has authority. This transfer will only occur if the third party agrees to use your data in compliance with all physical safeguards and in a manner at least as protective as stated in this Privacy Policy.

  • Aggregate Information

Bematur may disclose non-identifiable aggregate information for various purposes, including describing the services provided by Bematur to potential partners and other third parties.

  • Use of Social Media Plugins

When you visit our websites, integration ensures that your browser does not automatically connect with the servers of service providers. You only allow data transfer by enabling these plugins, which create a direct connection to the servers of the provider. The content of various plugins is then transmitted directly to your browser by the relevant service provider and displayed on your screen.

The plugin informs the service provider which pages of our website you visit. If you are logged into your Facebook or Twitter account while browsing our website, the service provider may collect data about your interests, such as the information accessible via your user account. When you use any plugin function (for example, clicking the “Like” button or posting a comment), this information is also transmitted directly by your browser to the service provider for storage.

You can find more detailed information about data collection and usage by Facebook or Twitter and the rights and options available to protect your privacy under these conditions at the data protection/privacy guidance of the respective service providers:

Facebook Data Protection/Privacy Guidance: http://www.facebook.com/policy.php

Twitter Data Protection/Privacy Guidance: https://twitter.com/privacy

9. Retention Periods of Your Personal Data

The retention periods of your personal data are as follows:

If a retention period is specified in the law or relevant legislation, the data in question must be retained for at least that duration. Considering possibilities such as a court request or a request from an administrative authority authorized by law arriving late, or the occurrence of a dispute in which we may be involved, the retention period of your data is determined by adding an additional 6 months to 1 year to the periods prescribed by legislation. At the end of the determined period, the relevant data is deleted.

If the legislation does not specify a retention period for the data we process, your data will be retained for the duration necessary to fulfill our relationship and the period specified in the contract concluded with you. After this relationship ends or the contractual period expires, your data will be deleted, destroyed, or anonymized without the need for any request from you.

If you request the early deletion of data for which a retention period is legally prescribed, your request cannot be fulfilled.

If your data is not subject to a legally defined retention period and has no processing purpose, and you request its deletion, it will be deleted immediately or at the latest within 6 months.

10. Deletion, Destruction, or Anonymization of Personal Data

Personal data processed in accordance with the purposes stated in the Personal Data Information Notice will, pursuant to Article 7/1 of Law No. 6698 on the Protection of Personal Data (KVKK), be anonymized and continue to be used by us when the purpose requiring its processing no longer exists.

11. Your Rights Regarding Your Processed Personal Data

In accordance with Article 11 of the Law, the personal data owner has the right to apply to Bematur to:

a. Learn whether their personal data is being processed,
b. Request information if their personal data has been processed,
c. Learn the purpose of processing their personal data and whether it is being used in accordance with that purpose,
d. Know the third parties to whom their personal data has been transferred, domestically or abroad,
e. Request the correction of their personal data if it is incomplete or inaccurate, and request its deletion or destruction in accordance with the conditions set forth in Article 7 of the KVKK,
f. Request notification of the actions taken regarding third parties to whom their personal data has been transferred in accordance with (d) and (e) above,
g. Object to any result that arises against them due to the exclusive analysis of their personal data through automated systems,
h. Request compensation for any damages incurred due to the unlawful processing of their personal data.

Requests submitted within this scope will be processed by Bematur free of charge within thirty days at the latest. However, if a fee is prescribed by the Personal Data Protection Board, the fee specified by our company’s tariff will apply.

12. Methods for Exercising Your Rights Regarding Your Processed Personal Data

It is important, in terms of Law No. 6698 on the Protection of Personal Data (KVKK) and other relevant legislation, that the personal data you share with us is kept accurate and up-to-date. Therefore, you can easily make any changes or updates to your personal data by submitting documents verifying your identity in person or by mail to Bematur at [address], Tepebaşı/Eskişehir, or by contacting us via email at rezervasyon@bematur.com. This ensures that any errors are prevented and facilitates the accurate and up-to-date protection of the personal data we maintain.

According to the Communiqué on the Procedures and Principles of Application to the Data Controller, the application must include the applicant’s first and last name, signature if the application is in writing, Turkish ID number (or passport number if the applicant is a foreigner), address for notification purposes or workplace address, if available the email address used for notification, phone number, fax number, and information regarding the subject of the request.

The applicant must clearly and comprehensibly state the request in the application, including explanations related to the right they wish to exercise. Supporting documents and information related to the request must be attached to the application.

While the subject of the request must relate to the applicant personally, if someone is acting on behalf of another person, the applicant must have specific authorization for this purpose, and such authorization must be documented (special power of attorney). Additionally, the application must include identity and address information, and documents verifying the applicant’s identity must be attached.

Requests submitted by unauthorized third parties on behalf of another person will not be considered.

13. User Declaration

In accordance with the Personal Data Protection Law, I hereby acknowledge that I have received, read, reviewed, and evaluated the above information notice regarding the processing of my personal data by Bematur and its affiliates and subsidiaries mentioned in the text on the date specified below. I declare that I accept all the matters stated above knowingly and voluntarily.

I also consent to the processing and sharing of my personal data, as defined in the KVKK, for the purposes and reasons specified in this “Personal Data Information Notice,” including the content, collection location, and method described above, with the individuals stated above, provided that my rights to claim and litigate for any damages arising from your Company’s fault or negligence during the implementation of these matters remain reserved.

Company Name: Bematur
Address: Gayrettepe Neighborhood Barbaros Boulevard No:161 Floor 6 Flat 11, Besiktas / Istanbul
E-mail: rezervasyon@bematur.com
Phone: [telefon

Our Company Bematur (FİRMA URL) treats the security of your personal data with the utmost importance. All personal data held by our company are processed, stored, and transferred in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”). This information text has been prepared in accordance with Article 10 of the Law, titled “The Data Controller’s Obligation to Inform,” regarding the personal data collected, stored, and processed by FİRMA URL as the “Data Controller.”

Within the scope of the “KVKK and Privacy Policy” shared with you by Bematur, your explicit consent is requested for the processing of your personal data under Bematur in the ways specified below, along with the cases where processing is legally permissible.

1. Purposes of Processing Personal Data Under

Law No. 6698, personal data is defined as any information belonging to an identified or identifiable natural person. Any data that falls within this scope is evaluated by our Company in accordance with relevant legislation. Personal data may be processed for purposes including, but not limited to:

Providing Company services and performing necessary operations related thereto,

Contacting you regarding our services if explicit consent is provided,

Conducting marketing activities,

Customer acquisition and sharing related service offers,

Reporting, customer statistics, and similar analyses necessary for Company operations.

2. Collection of Personal Data and Legal Basis

Personal data may be collected through websites, customer communications, designs, and other verbal, written, or electronic channels for the purposes described above. Such data are processed, transferred, and stored in line with these purposes.

3. Transfer of Personal Data

The Company may share personal data with the following parties for the purposes described above:

Relevant departments providing services to continue Company operations and business processes,

Domestic and/or international service providers processing personal data on behalf of the Company,

When necessary, official authorities, supplier companies, public institutions, business partners, and insurance companies.

Personal data will not be transferred outside these purposes or in ways incompatible with Company activities without the explicit consent of the data subject.

4. Your Rights Regarding Your Processed Personal Data

Under Article 11 of the Law, the data subject has the following rights: a. To learn whether personal data is processed, b. If processed, to request information about it, c. To learn the purpose of processing and whether personal data is used appropriately, d. To know third parties to whom personal data is transferred domestically or abroad, e. If personal data is incomplete or incorrect, to request correction or, under the conditions specified in Article 7 of the KVKK, deletion or destruction, f. To request notification of the actions taken pursuant to (d) and (e) regarding third parties to whom personal data is transferred, g. To object to results that arise solely from automated systems processing of personal data that adversely affect them, h. To demand compensation if damages occur due to unlawful processing of personal data.

Requests will be concluded free of charge within 30 days by the Company. However, if a fee is stipulated by the Personal Data Protection Board, the Company will charge according to the tariff determined.

5. Explicit Consent for the Processing of Personal Data

In accordance with Law No. 6698 on the Protection of Personal Data (“KVKK”), I have been informed about the processing of my personal data by Bematur, the purposes of processing, the recipients and purposes of transfer, the methods and legal basis for collection, and my other rights listed in Article 11 of KVKK.

Within this scope, I acknowledge that I have been fully informed, that I have read, understood, reviewed, evaluated, and approved the “KVKK and Privacy Policy,” and I accept and consent—of my free will—to the processing of my personal data for the purposes and reasons stated therein, the sharing of such data with the parties listed above, and processing within the scope defined by the KVKK. This is without prejudice to my rights to seek compensation or file a lawsuit in case of damages resulting from the Company’s fault or negligence.

Contact for Your Requests If you wish to contact us,

provide feedback, or submit questions under Law No. 6698, you may do so by delivering your request in person or via a notarized document along with documents proving your identity to Gayrettepe Neighborhood Barbaros Boulevard No:161 Floor 6 Flat 11, Besiktas / Istanbul, or by contacting us at rezervasyon@bematur.com.

Written requests will be accepted after identity verification and responded to within the legal time frame.

Detailed information about the purposes for which your personal data are processed can be accessed through the publicly shared texts:

“[KVKK and Privacy Policy]” at DETAYLI BİLGİ URL

“Cookie Policy” at DETAYLI BİLGİ URL