PRIVACY NOTICE FOR COMMUNICATION ACTIVITIES

Data Controller:

Odeon Turizm İşletmeciliği A.Ş.

Ayazağa Mah., Azerbaycan Cad., 2B, No: 3K, İç Kapı No: 27 Sarıyer / İstanbul

As Odeon Turizm İşletmeciliği A.Ş. (hereinafter referred to as “Odeon”), we attach great importance to the security of your personal data that we process in our capacity as data controller as defined in the Personal Data Protection Law No. 6698 (“KVKK”). Therefore, we would like to inform you about the processing of your personal data.

Within the scope of communication activities, your identity information (name, surname), contact information (e-mail address, phone number), transaction information (request/complaint/suggestion information), website records (IP address information, website entry/exit information, log records, device MAC address information) will be collected through Odeon's communication tools, online electronic forms, and information processing technologies. This data will be processed for the purposes of conducting communication activities, following up on requests/complaints, conducting customer relationship management processes, conducting post-sales support services for goods/services, conducting necessary research/investigations to provide support services regarding the subject of the request, providing you with information and support services, and managing information security processes.

Your identity, communication, and transaction information will be processed on the following legal grounds as per subparagraph (c) of clause 2 of article 5 of the KVKK  “The necessity of processing of personal data belonging to the parties of a contract is directly related to the establishment or performance of a contract” and subparagraph (f) “The processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject”

Website records shall be processed based on the legal grounds set forth in Article 5, Paragraph 2, Subparagraph (ç) of the KVKK; “It is necessary for the data controller to fulfill its legal obligations,” and (f) “processing is necessary for the legitimate interests of the data controller, provided that this does not harm the fundamental rights and freedoms of the data subject.”

To Whom and for What Purposes May Your Personal Data Be Transferred?

Your personal data will be transferred in accordance with the rules set forth in Article 8 of the KVKK regarding domestic transfer and by taking the necessary technical and administrative measures;

●    To Authorized Public Institutions and Organizations, for the purposes of conducting activities in accordance with the legislation, providing information to authorized persons, institutions, and organizations, and following up and conducting legal affairs, if necessary;

●          To Affiliates for the purposes of conducting/monitoring business activities, conducting communication activities, and providing after-sales support services for goods/services, only to the extent necessary to achieve the relevant purposes.

What are your rights regarding your personal data as the data subject?

Regarding your personal data you have the following rights;

●      Learn whether your personal data is being processed,

●      Request information regarding the processing of your personal data,

●      Learn the purpose of the processing of personal data and whether they are used in accordance with their purpose,

●      Know the third parties to whom your personal data has been transferred within or outside the country,

●      Request the correction of your personal data if it has been processed incompletely or incorrectly,

●      Request the deletion or destruction of your personal data within the framework of the conditions stipulated in KVKK,

●      If you request the correction of incomplete or incorrect data and the deletion or destruction of your personal data, you may also request this situation to be reported to third parties to whom we have transferred your personal data,

●      Object to decisions made solely through automated processing of your data that adversely affect you, and

●      Request compensation for any damages incurred due to the unlawful processing of your personal data.

How Can You Exercise Your Rights?

You may submit your requests and applications regarding your personal data through the Data Subject Request Form available on our website;

●    By sending a genuinely signed copy along with a photocopy of your ID to the address: Ayazağa Mah. Azerbaycan Cad. No: 3k İç Kapı No: 27 Sarıyer İstanbul,

●          By applying in person to Odeon with a valid identity document,

●    By signing with a mobile signature or secure electronic signature and sending it by email to [email protected],

●          By sending it to our registered electronic mail (KEP) address [email protected] using a registered electronic mail address and secure electronic signature or mobile signature,

●    By sending it to our address [email protected] from the email address previously reported to Odeon by the Data Subject and registered in our system.

In accordance with the Circular on Procedures and Principles for Applications to the Data Controller, the Data Subjects’ application must include their name, surname, signature (if the application is in writing), Turkish ID number (if the applicant is a foreign national, their nationality, passport number, or ID number, if any), address of residence or place of work for notification purposes, email address for notification purposes (if any), telephone number, fax number, and information regarding the subject of the request.

The Data Subject must clearly and comprehensively state the subject of the request in the application, which must include explanations regarding the rights they wish to exercise and the rights they wish to use. Information and documents related to the application must be attached to the application.

The subject matter of the request must relate to the applicant themselves; however, if the request is made on behalf of another person, the applicant must be authorized to do so and this authorization must be documented (power of attorney). If the request involves special category data, the person making the request must be specifically authorized to do so in accordance with Article 10 of the Regulation on Personal Health Data. In addition, the request must include identity and address information, and documents verifying the identity must be attached to the request.

Requests made by unauthorized third parties on behalf of others will not be considered.

How Long Does It Take to Respond to Your Requests Regarding the Processing of Your Personal Data?

Your requests regarding your personal data will be evaluated and responded to as soon as possible and within 30 days at the latest from the date we receive them. If your request is accepted or rejected with an explanation of the reasons, our response will be sent to you via the address you specified in your application, primarily by post or email, and, if possible, by the method you used to submit your request. If the evaluation and decision-making process incurs additional costs, the fee determined by the Personal Data Protection Board will be applied.