ENLIGHTENMENT TEXT FOR THE GUEST

Ela Excellence Resort Belek

PROTECTION OF PERSONAL DATA

This information is hereby provided by Aktay Otel İşletmeleri A.Ş. (“Ela Hotel”) as the data controller under the provisions of the obligation to enlighten the data controller regulated in Article 10 of the Law No. 6698 on the Protection of Personal Data (“LPPD”).

Processing Your Personal Data, Its Purpose and Legal Cause

1. Personal Data Processed Due to Accommodation and Services Taken

a. Ela Hotel processes your credentials (name, surname, date of birth, Turkish ID number), Contact details (address, e-mail address, phone number) Accommodation information (room number), Customer Processes (call centre and hotel solution centre records, request-complaint records, payment details, billing details), security of physical space (entry and exit logs of guests to and from the hotel, security footage, licence plates of vehicles), and if you use of the Ela Holiday Assistant, the data you share there, process security (log and traffic data if you use the Wi-Fi network of the Ela Hotel), and details of the people who stay with you are.

These personal data are processed for the following main purposes: carrying out accommodation procedures under the service contract between our customers and us. providing support during and after the service. improving the service quality. maintaining communication. managing customer relations processes. rendering personalised services to you. accounting. managing accounting, finance, and legal processes. conducting your accommodation insurance procedures. and allowing you to connect to the Wi-Fi network. The related personal data are processed in accordance with Article 5 of the LPPD on the legal grounds that they are required by law (Tax Procedure Law, Identity Notification Law, Consumer Law, Law No. 5651, and other relevant legislation), that data processing is mandatory for the execution and performance of the contract, the establishment and protection of a right, and that it is necessary for the legitimate interest of the data controller.

b. to ensure customer satisfaction and quality standards and improve services, auditory recordings (reception, call centre and hotel solution centre interview voice recordings) are processed under Article 5 of the LPPD on the grounds that data processing is mandatory for the execution and performance of the contract, the establishment and protection of a right, and that it is necessary for the legitimate interest of the data controller.

2. Personal Data Processed for Sending Commercial Messages: Your credentials (name, surname) and contact details (telephone, e-mail addresses), your choices and preferences regarding your accommodation and the service you receive, and the personal data you provide through Ela Holiday Assistant will be processed for informing you about our campaigns, products, and services and sending SMS, calls, e-mails, and commercial messages based on your explicit consent.

3. Your Personal Data Processed through Ela Excellence Hotel Mobile App: During your stay, we also offer our valued customers the services covered by the hotel and accommodation through the mobile app. Your personal data acquired to make you benefit from the restaurants in the Ela Excellence Hotel App, accommodation bookings, and the service groups under the Services category in the App are processed based on the legal grounds of the execution or performance of a contract and the establishment of a right under Article 5/2 of the LPPD.

4. Your Personal Data on Social Media Posts: Your public photographs and videos that you have posted on social media concerning your stay at Ela Hotel may be posted on Ela Hotel’s social media accounts based on the legal ground of “making public by the data subject himself/herself” if you tag Ela Hotel accounts.

5. Audio and Visual Recordings from Events and Organisations: Photographs and video footage shot in spaces open to hotel guests or public participation or in shooting sites during events and organisations held at Ela Hotel are processed to be shared on social media and digital channels. If you prefer to appear in the places where photographs and videos are shot in this way, your personal data are processed and shared under Article 5 of the LPPD based on the legal ground of “making public by the data subject himself/herself”.

a. Method for Collecting Your Personal Data

i. Your personal data are processed through the forms you fill out at the reception desk, digital forms you fill out on websites, requests and communications during your stay in the hotel, online applications, cookies, digital forms, digital marketing technology tools, call centre, mobile apps, e-mails, search engines, 3rd party websites that share data with us based on your consent, social media channels and physical media and agencies, printed forms, our dealers, sales and marketing officials as well as direct communication, membership forms of our agencies, travel companies, tour operators, targeting, profiling, online behavioural advertising methods, automatic and non-automatic methods through our solution partners. A closed-circuit camera system at our hotel monitors security footage in the common spaces.

b. Transfer of Your Personal Data, Its Purpose and Legal Cause

6. Your Personal Data is shared with our “Suppliers” and “Business Partners” with whom we maintain a business relationship and from whom we procure services for the performance of the contracts we have concluded for the procurement of necessary outsourced services, required for our activities and limited to only this purpose, based on the legal reasons that data processing is mandatory for the legitimate interests of the data controller under Article 5/2 of the LPPD, the establishment or performance of a contract, the establishment, exercise or protection of a right. For example. your personal data is shared with Attorneys from whom we procure services due to a legal dispute, Financial Advisors from whom we procure services due to financial obligations, Auditors in case of audits, Travel Agencies and Companies from whom you make reservations and purchases under the procedures required for the performance of the contract, Banks from which the payments are made if necessary for the transactions related to the payment of accommodation, Suppliers and Business Partners of such services in cases where it is necessary to procure outsourced services related to your accommodation and our services, as well as our Group Companies (Özak Global Holding A.Ş., Özak Gayrimenkul Yatırım Ortaklığı A.Ş., Kamer İnşaat Ticaret ve San. A.Ş.), Subsidiaries and Affiliates from whom the related service is procured due to the performance of some services provided centrally, limited to the purpose necessary for the procedures.

7. The identity and check-in and check-out registers of the hotel guests are transferred to the General Law Enforcement Bodies and the State Institute of Statistics based on the legal cause prescribed by law and the fulfilment of the legal obligation of Ela Hotel under Article 2 of the Identity Notification Law.

8. Your name, surname, Turkish ID, and accommodation date details are transferred to “Insurance Agencies” to process insurance procedures during your stay in our hotel and for the protection of a right limited to such procedure since the data processing is mandatory for the establishment and protection of a right.

9. Your processed personal data shall be shared with our principal shareholders, especially Özak Global Holding A.Ş., Özak REIT A.Ş., Akyön Tesis Yönetim Hizmetleri A.Ş., Kamer İnşaat Ticaret ve San. A.Ş., ÖYZ Adi Ortaklığı, our subsidiaries, group companies and affiliates, as well as service providers, utilised for CRM, sending SMS and e-mails, making calls, domestic and foreign software, servers, agencies and service providers and data processors that render services necessary to carry out our activities, provide support for assessment, targeting and profiling, and İleti Yönetim Sistemi A.Ş. based on your explicit consent, to send you commercial electronic messages about other services and products.

10. Your personal data are transferred to “Public Authorities and Bodies” for Ela Hotel to fulfil its obligations to share information and documents required by the law, to exercise their legal rights, or to settle a legal obligation if there is an urgent or compulsory health requirement, if data processing is mandatory for the protection of an established right, it is mandatory for the protection of life or bodily integrity of the person or of any other person who is bodily incapable of disclosing his consent or whose consent is not deemed legally valid, it is required and/or necessary for the legal grounds. (e.g., Courts, Police, Law Enforcement, Consumer Arbitration Committees)

11. Your Rights

To the extent that your data is processed by Ela Hotel, you have the rights in Article 11 of Law No. 6698 on the Protection of Personal Data.

You may submit your requests within the scope of Article 11 of the Law regulating the rights of the data subject to the data controller in writing According to the “Communiqué on the Procedures and Principles of Application to the Data Controller” or by registered electronic mail (REM) address, secure electronic signature, mobile signature or by using the electronic mail address previously provided to the data controller by the data subject and registered in the system of the data controller.

Title of Data Controller: Aktay Otel İşletmeleri A.Ş.

MERSİS No: 42035466300014

REM Address: aktayotelas@hs01.kep.tr

Postal Address: Kazlıçeşme Mahallesi Kennedy Cad. No: 52 C/4 Zeytinburnu/Istanbul Zeytinburnu Tax Office. /0420354663

Electronic Mail Address: kvkk@ozakglobal.com