Cookie Policy

COOKIE POLICY                                                    

1. Purpose

The purpose of this Cookie Policy is to inform users who visit our company's website about cookies and similar technologies placed on their devices, to explain the purposes for which these technologies are used, and to state how users can manage their preferences.

In its personal data processing activities carried out through the website, our Company acts in compliance with Law No. 6698 on the Protection of Personal Data, related secondary legislation and other applicable regulations.

This Policy also aims to provide transparency regarding the categories of cookies used, their purposes of use, legal grounds, retention periods, relationships with third parties, and how users can manage their cookie preferences.

Within the scope of this Policy, our Company may act as data controller or, where applicable, as data processor with respect to personal data processed through cookies, depending on the nature of the specific processing activity.

2. Scope

This Policy covers;

• website visitors,
• users making online reservations,
• persons using the contact form,
• mobile device users,
• all natural persons receiving services through the website. 

This Policy covers personal data processing activities carried out through cookies and cookie-like technologies used on the website.

3. What Is a Cookie?

A cookie is a small text file saved by websites on users' computers, mobile phones or other devices.

Thanks to cookies;

• the website can operate more efficiently,
• user preferences can be remembered,
• session management can be provided,
• security can be enhanced,
• visitor experience can be improved,
• the performance of the website can be analyzed.

Depending on their purposes of use and technical characteristics, cookies and similar technologies may store information on a device or read information from it.

The manner in which cookies are stored on and accessed from a device may vary depending on the type of cookie, its technical structure and the technology used.

4. Types of Cookies

4.1 By Duration

Session Cookies

These are temporary cookies that are deleted when the browser is closed.

They may be used for session management and security purposes.

Persistent Cookies

These are cookies that are stored on the device for a specified period.

They may be used to remember user preferences.

The retention period of persistent cookies may vary depending on the technical characteristics and purpose of the cookie. The current cookie name, provider and retention period are displayed in the cookie management panel or the relevant cookie list presented on the website.

4.2 By Purpose of Use

Strictly Necessary Cookies

These are cookies required for the website to function properly.

Without these cookies, some parts of the website may not work.

These cookies may be used, based on the legal grounds provided in the relevant legislation, to the extent strictly necessary for providing the website or a service explicitly requested by the user. In cases where explicit consent is not required, offering a cookie preference does not mean that strictly necessary cookies can be blocked.

Functional Cookies

These are used to remember user preferences.

For example;

• language selection,
• currency,
• session preferences.

Where functional cookies are not strictly necessary and their use does not rely on another legal ground, they may be used by offering the user an active choice.

Performance and Analytics Cookies

They may enable measurement, analysis and statistics regarding the use of the website. Whether the data obtained through these cookies is truly anonymous is assessed according to the techniques used and the nature of the data processing activity. Where personal data is processed, an appropriate legal ground must exist.

Thanks to these cookies, the aim is to improve service quality by analyzing;

• pages visited,
• error logs,
• visit durations,
• usage intensity.

Non-strictly necessary performance and analytics cookies, for which no valid personal data processing condition other than explicit consent exists, are not activated unless the user has actively opted in beforehand.

Advertising and Marketing Cookies

They may help deliver content and advertisements tailored to the user's interests.

Such cookies may be used where an appropriate legal ground exists for personal data processing and, in cases required by the relevant legislation, the user's prior explicit consent has been obtained. Where explicit consent is required, advertising and marketing cookies are not activated unless the user makes an active choice.

5. Data Processed Through Cookies

The following information may be processed through cookies:

• IP address,
• Browser type,
• Operating system information,
• Device information,
• Session information,
• Page view information,
• Click behavior,
• Website usage duration,
• Preference information,
• Cookie identification numbers.

The nature of data obtained through cookies may vary depending on the type of cookie and the relevant processing activity on the website. Even where cookies are not intended to directly obtain identity information, cookie identifiers, IP addresses or similar information may acquire the nature of personal data when associated with other data.

 Accordingly, data processed through cookies is evaluated within the scope of personal data legislation based on the nature of the specific processing activity.

6. Purposes of Using Cookies

Our Company may use cookies for the following purposes:

• Ensuring the security of the website,
• Improving user experience,
• Providing session management,
• Ensuring the technical operation of the website,
• Detecting errors,
• Carrying out performance analyses,
• Managing reservation processes,
• Remembering user preferences,
• Conducting statistical analyses,
• Enhancing service quality.

 In addition, depending on the nature of the relevant cookie, cookies may also be used to perform the core functions of the website, ensure security, provide services requested by the user, detect technical issues, and carry out measurement/analysis in compliance with the law.

 For cookies serving advertising, marketing or non-strictly necessary analytics purposes, it is essential that a valid legal ground exists for the relevant processing activity and, where required, that the user's prior explicit consent is obtained.

7. Legal Grounds for Cookies

Cookies are used on the basis of the following legal grounds:

• Being expressly provided for by law,
• Establishment or performance of a contract,
• The legitimate interest of the data controller,
• The explicit consent of the data subject (where required).

Non-strictly necessary cookies are activated, where required, subject to the user's preference.

However, it is not accepted that a single legal ground applies to all cookies. For each cookie or cookie category, the appropriate legal ground is determined separately, taking into account the purpose and nature of the personal data processing activity.

For non-strictly necessary cookies requiring explicit consent, explicit consent must be given in advance, relating to a specific subject, based on information, and freely. Users not making any selection is not accepted as having given explicit consent.

It is essential that non-strictly necessary cookies are not pre-activated in the cookie management panel, and that users are provided with the ability to accept, reject and later change their preferences.

8. Third-Party Cookies

Depending on the nature of the services offered, cookies belonging to third-party service providers may be used on our website.

Examples include;

• website performance analysis services,
• map services,
• online reservation infrastructures,
• security verification services,
• advertising and marketing tools,
• social media integrations.

 Cookies used by third-party service providers are subject to the respective provider's own privacy and cookie policies.

Our Company is not directly responsible for the data processing activities of third-party service providers. However, data security and personal data protection obligations are taken into account when selecting business partners.

Information such as the cookie provider, name, purpose, retention period and whether the cookie is subject to user preference is displayed in the cookie management panel on the website or in the current cookie list, to the extent available.

9. Managing Cookie Preferences

When users first visit our website, they can manage their preferences for non-strictly necessary cookies through the cookie preference panel displayed to them.

Users may;

• accept certain cookie categories,
• reject them,
• change their preferences later.

Strictly necessary cookies are used to enable the website to perform its core functions, and if they are disabled, some parts of the website may not function as expected.

Non-strictly necessary cookies requiring explicit consent are not activated without an active choice by the user.

Users must be able to withdraw their explicit consent later with the same ease. Withdrawal of consent may be carried out by a method as easy as giving it.

Withdrawal of consent does not affect the lawfulness of data processing activities carried out based on consent prior to its withdrawal.

10. Controlling Cookies Through Browser Settings

Users may manage, delete or block cookies through the settings of the internet browser they use.

As a result of changes made in browser settings;

• existing cookies may be deleted,
• saving of new cookies may be blocked,
• different preferences may be set for specific websites.

Disabling cookies may cause some features of the website not to function properly.

Using browser settings is an alternative method that may not fully replace the preference management option offered through the cookie preference panel on the website. However, blocking certain strictly necessary cookies may affect the operation of the website's core functions or the services requested by the user.

11. Transfer of Personal Data

Personal data obtained through cookies may, limited to the processing purpose, be transferred;

• to information technology service providers,
• to companies providing website infrastructure services,
• to analytics and performance service providers,
• to public institutions and organizations legally authorized, within the framework of the relevant legal provisions.

In case of transfer of personal data abroad, the transfer conditions set out in Article 9 of Law No. 6698 and the related secondary legislation in force at the time of the transfer are complied with.

Where transfers abroad take place, the purpose of the transfer, the recipient or recipient group, and the applicable legal mechanism are presented to the user in accordance with the nature of the processing activity, through the relevant information notices and/or the cookie management panel.

For transfers abroad, the applicable legal mechanism among adequacy decisions, appropriate safeguards, or the exceptional transfer cases provided in the Law is applied. Where standard contracts are used as an appropriate safeguard, the notification and other obligations provided in the legislation are fulfilled.

12. Measures for the Protection of Personal Data

Our Company implements appropriate technical and administrative measures to ensure the security of personal data obtained through cookies.

Within this scope, measures such as;

• access authorization,
• strong password policies,
• firewall applications,
• use of up-to-date software,
• secure data transfer,
• regular system checks,
• employee awareness training are applied.

The technical and administrative measures implemented may be updated taking into account the nature of the data processed, the scope of the processing activity and technological risks.

13. Rights of the Data Subject

Under Article 11 of Law No. 6698 on the Protection of Personal Data, data subjects may apply to the data controller and, within the conditions set out in the law, have the right to;

• Learn whether their personal data is being processed,
• Request information about it if it has been processed,
• Learn the purpose of processing and whether it is used in accordance with that purpose,
• Know the third parties to whom personal data is transferred domestically or abroad,
• Know the third parties to whom personal data is transferred,
• Request the correction, deletion or destruction of personal data within the conditions set out in the law,
• Request that third parties to whom personal data has been transferred be notified of such correction, deletion or destruction,
• Object to the occurrence of a result against the person through analysis of processed data exclusively by automated systems,
• Claim compensation for damages arising from unlawful processing of personal data,
• Exercise other rights provided by the law.

Applications are evaluated and concluded within the procedures and time limits provided in the relevant legislation.

Data subjects may apply through the current application channels of our Company to exercise their rights. Information on the methods by which applications can be made is further specified in our Company's KVKK Information Notice and the relevant application procedure.

14. Updating the Policy

This Cookie Policy may be updated when deemed necessary due to;

• Changes in legislation,
• Technical changes made to the website,
• Changes in the cookie technologies used,
• Changes in the Company's activities.

The current policy enters into force upon publication on the website.

Material changes made to the policy that affect users' rights, preferences or personal data processing activities are communicated to users in accordance with the legislation.

In case of changes to the purposes of use, providers, retention periods or legal grounds of cookies, the cookie preference panel and related information mechanisms are also updated where necessary.

Document Information

Document Name: Cookie Policy

Document No: KVKK-09

Prepared by: ............................................

Reviewed by: ............................................

Approved by: ............................................

Effective Date: …… / …… / 20……