Our Confidentiality and Personal Data Policy

Security of your personal data is very important for us and your personal data will be stored in accordance with the conditions set forth in the applicable legislation in the most secure manner.

By completing the forms on our website  you shall be deemed as having consented to Astaş Holding A.Ş. and its group of companies (hereinafter to be referred to as “Astaş”) being able to  collect, store, process, utilize  and transfer to the 3rd persons (acting in the capacity of data processor in their relationship with Astaş)  any personal data that you have kindly shared with us in order to provide certain advantages to you and to send by means of phone, short message (SMS), e-mail etc. all kinds of electronic communications relating to the promotions, advertisements, sale, marketing, surveying and similar activities.

Your personal data includes but is not limited to the following: your contact details, reservation data, information on the accommodation that you visited ; your participation to a membership or loyalty program, your participation to a contest, lottery or marketing program, information on the products and services you purchased, your personal characteristics, your nationality and income level, passport number and date and place of issue, your travel history, invoice and account details and identity authentication relating to mobile invoices and payment information including your card number and other card details, your investment preferences, marketing and communication preferences, information on your vehicles, your feedback about our trademarks and facilities, your club and group memberships, information directly provided by you and all other information that you decided to give us or that can be obtained by us from the third persons.

In addition to that information, data collected during your visit to our premises or our project sites are also considered as personal data.

We may also collect your personal data from third parties including solution partners and social media services in accordance with the settings you made in these services about sharing your personal data. We may add this information to the information that we already filed about you or share the same with others in line with the requirements of this notice.

 

Information on the Protection of Personal Data

This information and elucidation form is prepared in connection with processing and transfer of “Personal Data” of real persons under the Law on the Protection of Personal Data numbered 6698 (“KVK Law”). All kinds of current information about you which you shared with our company under the law numbered 6698 will be considered “Personal Data”.

 

a. Data controller 

This information notice is given under the Law on the Protection of Personal Data numbered 6698 (“KVKK”) by Astaş, acting in the capacity of data controller in order to fulfill its obligation of informing its business partners, shareholders, customers and other real persons and legal entities with whom it has relations.

Security of your personal data is very important for us and your personal data will be stored in accordance with the conditions set forth in the applicable legislation in the most secure manner and for the statutory time period required under that legislation. Thus your personal data will be processed for actual and current, definite, clear and legitimate purposes in line with the law and rules of honesty and directly in connection with that purpose on a limited and reasonable basis and will be maintained for the time period required in the legislation or as needed for the specific purpose of processing

 

b. Specific purposes of processing Personal Data 

Your Personal Data may be collected on a written, verbal or electronic basis by automatic or non-automatic means, including our offices, call center and internet sites, social media, mobile applications, organizations and similar methods used by us depending on the service or product provided or activity carried out by our company. Your Personal Data will be processed as long as you use our products and services including necessary updates.


Your Personal Data collected by us, according to the conditions and purposes of processing Personal Data as required under articles 5 and 6 of KVK Law, can be used in relation to efforts of our business divisions to enable you to enjoy our products and services; customization and recommendation of our products and services in line with your preferences, usage habits and needs; ensuring legal and commercial security of our company and of the persons having business relations with us, (ensuring physical security and inspection of our administrative operations aimed at communication and our locations, evaluation of business partners/customers/suppliers (including authorized representatives and employees), legal compliance process, financial affairs etc.); defining and implementing our commercial and business strategies and execution of our human resources policies.

 

c. Specific parties to whom Personal Data processed by us will be transferred and specific purposes of transfer 

Your Personal Data may be collected/obtained by Astaş via different channels (including headquarters and sales offices of Astaş, offices and media of other subcontractors and business partners, call centers, internet sites, mobile applications and similar electronic platforms, promotions, launches and donations organized on social media and other publicly available media, your participation into training sessions, conferences etc or recording on written, verbal, audio or video basis through other group companies or contracted persons and entities or other physical and electronic environments etc.). Your Personal Data will be collected and processed based on your explicit consent for the purposes set forth under clauses (b) and (c) of this notice and when they are directly related to the performance of a contract as stipulated in clause (c) of the 2nd paragraph of article 5 of the Law on the Protection of Personal Data or when it is necessary for the data controller to fulfill its legal obligation under clause (ç) of the same paragraph or to establish, exercise or protect a right under clause (e) or protect the legitimate benefits of  Astaş given in clause (f) provided that no harm is given to the basic rights and freedoms of the Personal Data owner. 

 

d. Specific methods and legal reasons of processing Personal Data

Your Personal Data will be collected by Astaş via technical and process based methods used in different channels including internet site, mobile applications, call center and physical channels for legal reasons arising from applicable legislation, contract, claims, commercial practices and rules of honesty and in order for us to provide our services and products to you and carry out our commercial activities. Your Personal Data collected for above mentioned purposes will be processed and transferred for the purposes set forth in this Elucidation Notice and according to the conditions and purposes of processing Personal Data as required under articles 5 and 6 of the Law numbered 6698.

 

e. What are the rights available to you in connection with your Personal Data?

  • Learning whether Personal Data was processed,
  • Demanding information on the Personal Data so processed,
  • Learning specific purpose of processing and whether processed Personal Data was used for the intended purpose,
  • Learning the identity of third persons to whom Personal Data was transferred in and out of the country,
  • Demanding correction of Personal Data processed inaccurately or deficiently and notification of the third persons to whom Personal Data was transferred about this correction,
  • Demanding deletion or destruction of Personal Data processed in accordance with Law numbered 6698 and other laws upon termination of specific reasons of processing and notification of the third persons to whom Personal Data was transferred about this deletion or destruction,  
  • Objecting to the negative consequences arising from the analysis of Personal Data only by automated means,                        
  • Claiming remedy for the losses and damages incurred by you because of illegal processing of Personal Data, and
  • Demanding deletion, destruction or making anonymous of your Personal Data held by Astaş.

 

If you want to exercise any of your rights detailed above, you may send your written demand bearing your wet signature along with information necessary for us to identify you and specific rights you would like to exercise to the address of Astaş at Büyükdere Caddesi No:127 Astoria Kuleleri B Blok K:12 Esentepe 34394 Şişli Istanbul – Turkey or send an e-mail copy of your demand signed with secure electronic signature to our registered electronic mail address at info@astas-holding.com.


You are also required to express your demand clearly and in an easily understandable manner in the application to be filed by you in order to exercise any of the above mentioned rights available to you provided that the demand is directly related to your Personal Data or if you are acting on behalf of another person, provided you  have authority to file this application in his/her name and provide documentation confirming this authority and that application contains identity and address details with relevant identification documents enclosed to the application.


All applications to be filed by you for above mentioned purposes will be finalized as soon as practical and in any case, within 30 days. Currently filing application is not subject to any charges. However if finalization of the application requires additional costs, the fees indicated in the tariff determined by the Board of Protection of Personal Data may be charged.

 

f. International data transfer

Our company acts in cooperation with international brands and meet your valuable portfolio with others on certain platforms as part of this cooperation. You consent to sharing of your Personal Data with international brands having sites throughout the world in order to be used in that cooperation. We will strive to process your Personal Data according to the requirements set forth in this notice even if such requirements may be different in other countries. 

 

g. Revisions

This notice is subject to revisions to be made from time to time. These revisions will be effective once they are published on our web site.



    

Newsletter