The purpose of this document is to inform you about our policy on the protection of personal data and in particular about the data we collect, how we process them, for what purposes we use them and with whom we share them.
In accordance with the provisions of Regulation (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereafter referred as “GDPR”), ALYA (hereafter referred as “Company”) is responsible for the processing of your personal data within the framework of the Loyalty Program(s) under any name to which the website: www.alya.com.tr (hereafter referred to as the "Website") is an integral part.
It is specified that children and minors (under 18 years of age) cannot register on the Website.
Contact us: firstname.lastname@example.org
“Personal data” means any information relating to an identified or identifiable natural person; is deemed to be an identifiable natural person, a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more elements specific to his or her physical, physiological, genetic, psychological, psychological, economic, cultural or social identity.
“Processing” means any operation or set of operations, whether or not carried out using automated processes and applied to personal data or sets of personal data, such as the collection, recording, organisation, structuring, storage, adaptation or modification, extraction, retrieval, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, etc., of personal data or sets of personal data.
PROCESSING OF PERSONAL INFORMATION OF EUROPEAN ECONOMIC AREA (EEA) RESIDENTS
For individuals residing in the EEA, this Statement outlines that Company is obligated to provide to you, as well as certain rights you have with respect to the processing of your personal information, pursuant to applicable local laws.
Purposes and Legal Basis for Processing: The legal bases for Company’s processing activities include processing such information as necessary to comply with our contractual obligations, compliance with our legal obligations, protecting the safety of our employees, guests and others, for our legitimate business interests, and pursuant to your consent.
The particular legal basis for the processing of your personal information is based on the purpose for which such information was provided or collected:
· Loyalty Program Participation: We process the personal information obtained in connection with your participation in the Loyalty program on the basis of our contractual relationship with you and in furtherance of our business interests, including to personalize your use of our services and applications, to communicate news and promotional items, and to deliver personalized advertising and content.
· Surveys: Completion of surveys is voluntary – we process the information obtained from surveys on the basis of your consent and in furtherance of our business interests, including marketing, service improvements, and analytics.
· Event Profiles: We process the personal information obtained in connection with your event on the basis of our contractual relationship with you and for our business interests, including for marketing, service improvements, and analytics and service personalization.
· Social Media: Participation in Company-sponsored social media activities and offerings is voluntary - we process information obtained from social media participation on the basis of your consent and in furtherance of our related business interests, including for marketing, service improvements, and analytics and service personalization.
· Promotions and Sweepstakes: Participation in sweepstakes, contests and other promotional offerings is voluntary – we process the information obtained from such participation based on your consent and as necessary to administer the offering. We also use certain data for our business purposes, including for marketing, service improvements,
administration of our e-Folio program, and analytics and service personalization.
· Direct Marketing: We use your personal information to send you marketing messages on the basis of your consent. You may withdraw your consent for direct marketing communications at any time by contacting us at email@example.com or by following the unsubscribe instructions in the marketing message.
Retention: We retain personal information about you for the time necessary to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. Our retention policies reflect applicable statute of limitation periods and legal requirements.
Data Subject Rights: Residents of the EEA have the following rights:
Access, Correction and Erasure Requests: You have the right to:
· ask us to confirm whether we are processing your personal information
· receive information on how your data is processed
· obtain a copy of your personal information
· request that we update or correct your personal information
· request that we delete personal information in certain circumstances
Right to Object to Processing: You have the right to request that Company cease processing of your personal information:
· for marketing activities, including profiling
· for statistical purposes
· where such processing is based on our legitimate business interests, unless we are able to demonstrate a compelling legitimate basis for such processing or we need to process your personal information for the establishment, exercise or defense of a legal claim
Right to Restrict Processing: You have the right to request that Company limit the processing of your personal information:
· While Company is evaluating or in the process of responding to a request by you to update or correct your personal information
· Where such processing is unlawful and you do not want Company to delete your data
· Where Company no longer requires such data, but you want us to retain the data for the establishment, exercise or defense of a legal claim
· Where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request
Where we limit the processing of your personal information pursuant to your request, we will inform you prior to re-engaging in such processing.
Data Portability Requests: You have the right to request that we provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.
Submitting Requests: your requests may be submitted by in writing to firstname.lastname@example.org. We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester’s identity. We may charge you a reasonable fee for subsequent copies of data that you request.
Right to Withdraw Consent: You have the right to withdraw your consent to any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account). You may withdraw your consent to marketing activities by following the instructions on any marketing emails, or contacting email@example.com.
Segmentation (also referred to as profiling) and Automated Decision Making: We use personal information to divide large groups of consumers into sub-groups of consumers (known as segments) based on some type of shared characteristics such as geography, behavior, or demographics.
With your consent, we make automated decisions, meaning without human interference, using segmentation and/or your specific personal information to offer you certain benefits based on your characteristics (such as discounted room rates or other special offers based on your geography, behavior, or demographics).
International Data Transfers: We may transfer the personal information we collect about you pursuant to the purposes described in this Statement to countries that have not been found by the European Commission to provide adequate protection.
We use appropriate safeguards for the transfer of personal information among our affiliates in various jurisdictions, and where required, we have implemented European Union controller-to-controller standard contractual clauses or other such safeguards for such purposes. To obtain a copy of theses clauses or additional information on transfers, you may send your request to firstname.lastname@example.org