LOVA TURİZM İNŞ. SAN. TİC. LTD. ŞTİ.

PERSONAL DATA PROTECTION AND PROCESSING POLICY

1. INTRODUCTION

This Personal Data Protection and Processing Policy ("Policy") addresses the principles adopted by LOVA TURİZM İNŞ. SAN. TİC. LTD. ŞTİ. ("Company") in its personal data processing activities and the fundamental principles adopted to ensure compliance with the regulations in the Law on Protection of Personal Data No. 6698 ("Law").

2. SCOPE OF THE POLICY

Our priority is to provide you with enjoyable experiences and quality accommodation services. It is very important for us that you fully trust the Company and are satisfied with the services we offer. As part of our commitment to meeting your expectations, we have created this Policy. This Policy outlines our commitments to you and explains how the Company will use your personal data.

The Law regulates the protection of fundamental rights and freedoms of individuals, particularly the privacy of private life, in the processing of personal data, as well as the obligations and procedures that real and legal persons who process personal data must comply with.

The purpose of this Policy, prepared in consideration of the said Law, is to ensure compliance with regulations on the protection of personal data, to process the information obtained during the Company's activities in accordance with the Law without violating the privacy of private life, and to determine responsibilities and inform personal data owners and employees.

3. DEFINITIONS

Explicit Consent: Consent that is specific to a particular subject, based on information and expressed with free will.

Personal Data: Any information relating to an identified or identifiable natural person (e.g., name - surname, Republic of Turkey Identity Number, email address, postal address, date of birth, credit card number, bank account number, etc.).

Personal Data Owner: The natural person whose personal data is processed. Information related to legal entities is not within the scope of the Law.

Processing of Personal Data: Any operation performed on personal data, such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying, or preventing the use of personal data, wholly or partly by automatic means or otherwise as part of a data filing system.

Sensitive Personal Data: Data relating to race, ethnic origin, political opinions, philosophical beliefs, religion, sect, or other beliefs, dress and attire, association, foundation, or trade union membership, health, sexual life, criminal conviction, and security measures, and biometric and genetic data.

Data Controller: The natural or legal person who determines the purposes and means of the processing of personal data and manages the place where data is systematically kept (data filing system).

4. GENERAL PRINCIPLES IN THE PROCESSING AND PROTECTION OF PERSONAL DATA

Transparency: We will provide you with all the information while collecting and processing your personal data and will inform you about the purpose and recipients of the data.

Compliance with Laws: We will collect and process your personal data only for the processing purposes stated in this Policy.

Appropriateness and Accuracy: We will collect only the personal data necessary for data processing. We will take all necessary steps to ensure that the personal data we hold is accurate and up-to-date.

Retention: We will retain your personal data for the period prescribed by the relevant legislation or as long as necessary for the processing purpose.

Access, Correction, Objection: You can access, change, correct, or delete your personal data. You may object to the use of your personal data, especially if you do not wish to receive sales and marketing information. Information about the department to be contacted in this context (Article 13) is given below in the "Access and Changes" section.

Confidentiality and Security: We will ensure that the necessary technical and organizational measures are taken to protect your personal data against alteration, accidental or illegal loss, or unauthorized use, disclosure, or access.

Sharing and International Transfer: We may share your personal data with third parties (such as business partners and/or service providers) for the purposes stated in this Policy. When sharing or transferring this information, we will take appropriate measures to ensure its security.

5. WHICH PERSONAL DATA IS COLLECTED?

From time to time, we may request information about you and/or your family members, such as the following, as a Lova Hotel & Spa customer:

Contact details (e.g., last name, first name, phone number, email address)

Personal information (e.g., date of birth, nationality)

Information about your children (e.g., name, date of birth, age)

Your credit card number (for bank transactions and reservation purposes)

Your arrival and departure dates

Your preferences and interests (e.g., eating and drinking habits, room cleaning and maintenance, smoking/non-smoking room, preferred floor, bed linen type, newspaper/magazine type, sports, cultural interests)

Questions/comments during or after your stay at one of our establishments.

The information collected about individuals under the age of 18 is limited to name, nationality, and date of birth, and this information can only be provided to us by an adult. Please ensure that your child does not send us personal data without your consent (especially over the Internet). In the event that such data is sent, you can contact the Data Privacy Department for the deletion of the information ("Access and Change" section).

We do not deliberately collect sensitive personal data related to race, ethnic origin, political opinions, religious beliefs, or other beliefs, or trade union memberships, dress, and attire.

Information related to religion, health data, and sexual life is also considered sensitive personal data. To meet your needs or provide a service suitable for you, such as a special diet program, we may need to collect this information. In such a case, your explicit written consent will be obtained in advance, in accordance with the relevant provision of the Law.

6. WHEN ARE YOUR PERSONAL DATA COLLECTED?

Personal data may be collected in various circumstances, including:

Hotel activities:

Room reservations

Check-in and payment at the hotel

Eating/drinking at the hotel bar or restaurant during a stay

Requests, complaints, and/or disputes.

Participation in marketing programs or events:

Participating in customer surveys

Online games or contests

Subscribing to newsletters to receive offers and promotions via email.

Transmission of information from third parties:

Tour operators, travel agencies, GDS reservation systems, and others

Internet activities:

Connecting to Lova Hotel Spa websites (IP addresses, cookies)

Online forms (online reservation, surveys, pages on social networks such as Lova Hotel Spa, logging in through networks like Facebook).

7. FOR WHAT PURPOSES ARE YOUR PERSONAL DATA COLLECTED?

We collect your personal data for the following purposes:

To fulfill our obligations to our customers.

To manage room reservations and accommodation requests:

To create and store legal documents in accordance with accounting standards.

To manage your hotel stay:

To monitor your use of services (telephone, bar, pay TV, etc.)

To manage room access

Internal management of lists of customers who have shown inappropriate behavior during stays at hotels (aggressive and antisocial behavior, non-compliance with hotel contracts, non-compliance with security regulations, theft, damage, and vandalism or payment-related incidents).

To improve our hotel services, especially in the following areas:

To carry out marketing activities, promote brands, and better understand your needs and wishes by processing your personal data in a customer-oriented marketing program

To tailor our products and services to better meet your needs

To customize the commercial offers and promotional messages we send you

To manage our relationships with customers before, during, and after stays:

To provide details related to the customer database

To perform segmentation operations based on reservation history and customers' travel preferences to send targeted communications

To develop statistics and commercial scores and perform reporting

To know and manage the preferences of new or former customers

To manage unsubscribe requests from newsletters, promotions, tourism offers, and satisfaction surveys

To take into account the right to object

To use special telephone services to contact individuals staying at Lova Hotel & Spa in the event of serious incidents affecting the hotel (natural disasters, terrorist attacks, etc.).

To cross-check, analyze, and apply specific systems to your data by using a reliable third party, so that we can identify your interests and customer profile and offer you personalized offers during or after your reservation.

To improve Lova Hotel & Spa services, especially in the following areas:

To conduct surveys and analyze customer comments

To manage claims/complaints

To offer you the benefits of our customer loyalty program.

To secure and improve your use of Lova Hotel & Spa websites, especially in the following areas:

To improve navigation

To implement security and fraud prevention systems.

To comply with local laws (e.g., retaining accounting documents).

8. CONDITIONS FOR THIRD-PARTY ACCESS TO YOUR PERSONAL DATA

To provide you with impeccable service, we need to share your personal data with internal and external recipients under the following conditions, while granting access and modification rights:

a. To provide you with the best service, we may share your personal data with public authorities pursuant to court orders and law enforcement agencies under the Identity Notification Law, and we may grant authorized personnel within the Company access to your data, including:

Personnel

Information Technology departments

Commercial partners and marketing services

If applicable, medical services

If applicable, legal services

b. Service providers and partners: The Company may send your personal data to third parties such as the following to provide you with services and improve your stay:

External service providers: IT subcontractors, international call centers, banks, credit card companies, external lawyers, distributors, printers.

Suppliers: Limited transmission of personal data to suppliers to ensure the provision of necessary services to the Company.

Commercial partners: Unless otherwise specified to the Data Privacy Department, the Company may share some of your personal data with its preferred commercial partners to enhance your profile. In this case, a reliable third party may cross-check, analyze, and apply specific systems to your data. By processing data in.

Lova Tourism
Clarification Text for Lova Hotel & Spa Yalova Tourism Facility
This disclosure text is made by Lova Tourism Construction Industry Trade Ltd.Com (the "Company").

The company may request the following information / personal data from Lova Hotel & Spa customers and / or family members before and / or during or during / after the stay: Contact information, personal information, information about children, your credit card number, arrival and departure dates, accommodation preferences and interests, questions / comments during or after staying at one of the establishments.

The personal data in question is compulsory for the legitimate interests of the data controller within the framework of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law, provided that the data controller can fulfill his legal obligations and do not harm the fundamental rights and freedoms of the relevant persons ( fulfilling counter obligations, managing room reservations and accommodation requests, improving hotel services, etc.).

In order to provide the service standard offered all over the world and to provide better hotel services, the personal data in question can be shared with internal and external buyers within the framework of the personal data processing conditions specified in Articles 8 and 9 of the Law. In this regard, personal data may be transferred to the Company's service providers, suppliers, commercial partners and other legal disputes or to judicial authorities or relevant law enforcement agencies upon request in accordance with the relevant legislation.

Your requests regarding the rights you have as a data owner regulated  within the scope of Article 11 of the Law regulating the rights of the person concerned, Lova Tourısm Construction Industry Trade Ltd available at https://www.lovahotel.com/. Ltd.Com. If you submit it with the methods specified in the Personal Data Protection and Processing Policy, it will be evaluated and concluded within 30 (thirty) days. Although it is essential not to charge any fee for the requests, the Company reserves the right to charge a fee based on the fee schedule determined by the Personal Data Protection Board.

LOVA HOTEL SPA
INFORMATION ON INTERNET ACCESS AND USAGE
1. IDENTITY OF DATA CONTROLLER
Your personal data, as the data controller, LOVA TOURISM CONSTRUCTION INDUSTRY LTD COM ("Company"), in accordance with the Law on the Protection of Personal Data No.6698 ("Law"), the personal data of the person ("User") who uses wireless internet access within the borders of LOVA HOTEL & SPA campus can be processed within the scope described below.

2. WHICH DATA ARE PROCESSED?
Below are the data processed by the Company and considered as personal data in accordance with the Law. Unless otherwise explicitly stated, the term "personal data" shall cover the following information within the scope of the terms and conditions provided within the scope of this Clarification Text.

The user;
Name, surname, telephone number, IP address information, starting and ending time and information showing the unique network device number (MAC address) of the computers and other information stipulated in the Law No.5651 on the Regulation of Broadcasts Made on the Internet and Fight Against Crimes Committed Through These Publications. informations.

3.PURPOSE OF PROCESSING YOUR PERSONAL DATA
Your collected personal data can be processed by the Company for the following purposes, in accordance with the basic principles stipulated by the Law and within the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law:

• Managing the Wi-fi user profile: The company can collect and process the user's information in order to recognize the user as a authorized User and allow access to Wi-fi functions.

Internet browser control content: The Company can examine the user's internet surfing using wi-fi and collect information on the basis of standard usage parameters in order to prevent, prevent and stop the usage or activities of Users or third parties contrary to the authorized uses. • Data collection within the scope of the law: The Company, within the scope of the said legislation, regarding the cases where it is a hosting company pursuant to the Law No. 5651 on the Regulation of Broadcasts on the Internet and Fight Against Crimes Committed Through These Broadcasts,

• Using our right to legal defense in a possible legal dispute, investigation, judicial or administrative control and other situations,
• Execution of access authorizations,
• Carrying out information security processes,
• Carrying out activities in accordance with the legislation,
• Following and executing legal affairs,
• It is processed to ensure the security of data controller operations.

4. PARTIES TO WHICH YOUR PERSONAL DATA IS TRANSFERED AND TRANSFER PURPOSES
Your personal data in the presence of legal obligations or conditions of Articles 8/2 and 9/2 of the Law In accordance with the law and the rule of honesty, in a correct and up-to-date manner, provided that it is limited and measured within the scope of explicit and legitimate purposes; For the purposes of a possible legal dispute, investigation, judicial or administrative supervision and other cases such as exercising our right to legal defense, responding to other official or legal requests for information and documents, our company lawyer, legal and administrative authorities requesting information and our Company to achieve the stated objectives It is shared with third party persons or persons from whom it will receive services or with public institutions or organizations authorized to request this data as required by a legal obligation.

 5. METHOD OF COLLECTING YOUR PERSONAL DATA AND LEGAL REASON
Our company automatically collects your browser information, IP address, web access log records when you connect to the common internet network in its buildings; We process it by storing it on a physical server and cloud server and by creating a database, making lists, filling documents, writing a petition, filling out forms, etc., automatically or non-automatically, depending on the nature of the job and the nature of the personal data requested / processed.

6. RIGHTS OF THE PERSONAL DATA OWNER
Your requests within the scope of Article 11 of the Law "regulating the rights of the person concerned" are made to  LOVA TOURISM CONSTRUCTION INDUSTRY LTD COM. Termal way street. No: 3 / YALOVA in writing or to the e-mail address info@lovahotel.com in writing via e-mail.

Lighting Text About Closed Circuit Camera Recording Systems Located In Lova Hotel & Spa Tourism Facility

The text of this lighting is part 10 of the law on the protection of personal data No. 6698 (“law”). in accordance with the communique on the procedures and principles to be followed in the fulfillment of the lighting obligation with the article  LOVA TOURISM CONSTRUCTION INDUSTRY  prepared by ltd com (the“company”).

In our facility within the scope of tourism enterprise, there are 46 cameras in the register used in the service area of entrance doors, building exterior, lobby, restaurant, indoor parking lot, meeting room, gym and floor corridors within the closed circuit camera system. The registration process is supervised by the Technical Service Unit.

1. SCREEN 24 CAMERA		2. SCREEN 16 CAMERA
cam-1	Reception Desk	cam-1	Hotel Corner Main Road Entrance
cam-2	Lobby	cam-2	Hotel Entrance Door Front
cam-3	Lobby	cam-3	Parking in Front of the Hotel
cam-4	Lobby	cam-4	Hotel Front Gas Station Entrance
cam-5	Rear Parking	cam-5	Rear Parking
cam-6	1st Floor Customer Elevator Front	cam-6	Ground Floor Customer Elevator Front
cam-7	1st Floor Short Corridor	cam-7	Kitchen
cam-8	1st Floor Long Corridor	cam-8	Kitchen
cam-9	1st Floor Long Corridor	cam-9	Fitness Center
cam-10	1st Floor Service Elevator Exit Corridor	cam-10	Accounting Front Hall
cam-11	2nd Floor Customer Elevator Front	cam-11	Technical Front Hall
cam-12	2nd Floor Short Corridor	cam-12	Laundry Front Hall
cam-13	2nd Floor Long Corridor	cam-13	Staff Cafeteria
cam-14	2nd Floor Long Corridor	cam-14	Terrace Area Above Short Corridor
cam-15	2nd Floor Service Elevator Exit Corridor	cam-15	Parking Entrance Side Road
cam-16	Restaurant	cam-16	Gray Hall
cam-17	Outdoor pool	3. SCREEN 4 CAMERA
cam-18	L Cafe	cam-1	Spa Desk Area
cam-19	Staff Break Area	cam-2	Reception Desk
cam-20	Terrace Area Above Long Corridor	cam-3	3rd Floor Customer Elevator Front
cam-21	Reception Back Office	cam-4	White Hall
cam-22	Accounting
cam-23	Technical	cam-1	Kindergarten
cam-24	Kitchen	cam-2	Kindergarten

The personal data in question is subject to Article 5 of the Act. and 6. the conditions and objectives specified in the articles of the processing of personal data within the framework of the legal obligations of the principal data and the record data with the fundamental rights and freedoms of the persons concerned to harm the legitimate interests of the principal for the purposes of data processing to ensure the security of the facility and also be mandatory for processed. Such personal data is subject to act 8. and 9. in accordance with the terms and purposes of personal data processing specified in the articles, it may be transferred to judicial authorities or relevant law enforcement agencies upon request in accordance with the resolution of legal disputes or the relevant legislation.

As a data owner, within the scope of Article 11 of the Law regulating the rights of the person concerned,

a) learning whether personal data is processed,

b) request information about personal data if it has been processed,

c) learning the purpose of processing personal data and whether it is used in accordance with its purpose,

d) knowing the third parties to whom personal data is transferred at home or abroad,

e) request that personal data be corrected if it is incomplete or incorrectly processed, and request that the transaction made in this context be notified to third parties where the personal data is transferred,

f) processed in accordance with the provisions of this law and other relevant laws, although in the case of the disappearance of the reasons that require the processing of personal data and, in this context the deletion or destruction of the process request to be notified of the personal data transferred to third parties,

g) objecting to the occurrence of a result against the person himself by analyzing the processed data exclusively through automated systems,

h) if personal data is damaged due to illegal processing, you have the right to request the removal of the damage.

Your requests regarding your aforementioned rights are sent to LOVA TOURISM CONSTRUCTION INDUSTRY LTD.   If you submit it with the metods specified in the Personal Data Protection and Processing Policy, it will be evaluated and concluded within 30 (thirty) days. Although it is essential not to charge any fee for the requests, the Company reserves the right to charge a fee based on the fee schedule determined by the Personal Data Protection Board.