Protection of Personal Data

Last Updated : April 2020

1. The Parties
This personal data processing contract is arranged between Ideatec Bilişim Çözümleri Innly (hereinafter referred to as Innly) and www.innlyapp.com (hereinafter referred to as "site") and it is an integral part of the usage agreement.

2. Definitions
In this contract;

Explicit Consent: Consent on a particular subject, informed and expressed with free will.

Processing of Personal Data: Obtaining, saving, storing, preserving, modifying, reorganizing, disclosing, transferring, taking over, making it available, which is completely or partially automated or non-automated provided that it is part of any data recording system, any action taken on data, such as its classification or inhibition of its use.

Personal Data Owner: Real person whose personal data is processed.

Personal Data: All kinds of information about an identified or identifiable natural person. Therefore, the processing of information about legal persons is not covered by the Law. For example; name-surname, TCKN, e-mail, address, date of birth, credit card number, bank account number, etc.

Personal Data with Special Characteristics: Data on race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, disguise, association foundation or union membership, health, sexual life, criminal conviction and security measures and biometric and genetic data are special quality data.

Data Supervisor: The person who determines the purposes and means of processing personal data and manages the place where the data is kept systematically (data recording system) is the data officer.

Constitution: The Constitution of Turkey.

3. Considerations for the Processing of Personal Data
3.1. General Principles in the processing of personal data.
FR Hotel, Constitution of Turkey, Processing of Personal Data Act (hereinafter referred to as CTL) covered in other laws that have to comply Situated in accordance with the provisions on processing data.

In this context, we act in line with the following principles:

3.1.1. Compliance with Law and Honesty
As a prudent merchant, Innly acts in accordance with the general principles of trust and honesty in the processing of personal data with the principles brought by legal regulations.

3.1.2. Making Personal Data Accurate and Up-to-date When Required
The Innly ensures that the personal data it processes are accurate and up-to-date, taking into account the basic rights and legitimate interests of personal data holders under the KVK law, along with other laws that it must comply with within its activity.

3.1.3. Processing for Specific, Explicit and Legitimate Purposes
Innly sets out its legitimate and legitimate personal data processing purpose. In this context, personal data are provided or processed with limited services and legal obligations. In this context, for what purpose the personal data will be processed, it is determined before the personal data processing activity begins.

3.1.4. Being Connected, Limited and Metered for the Purpose They Are Processed
Innly processes personal data in a convenient way to achieve the specified goals and avoids processing personal data that are not related or needed to achieve the purpose. Accordingly, data processing is limited to activities and legal obligations.

3.1.5. Preservation for the Period Envisaged in the Relevant Legislation or Required for the Purpose
Innly retains personal data only for the period of time required for the purpose for which it is specified or processed in the applicable legislation.

3.2 Terms of processing personal data
Protection of personal data is a constitutional right. Fundamental rights and freedoms can only be restricted by law, regardless of their essence, only for the reasons stated in the relevant articles of the Constitution. Pursuant to the Constitution, personal data can only be processed in cases stipulated by law or with the consent of the person. Innly, in this direction and in accordance with the Constitution; It processes the personal data only in cases stipulated by law or with the express consent of the person.

The explicit consent of the personal data owner is only one of the legal bases that make it possible to process personal data lawfully. Apart from explicit consent, personal data may also be processed in the presence of any of the other conditions written below. The basis of the personal data processing activity can be only one of the following conditions, and more than one of these conditions may be the basis of the same personal data processing activity.

Data Owner
One of the conditions for processing personal data is the explicit consent of the owner. The explicit consent of the personal data subject should be disclosed on a specific subject, based on information and free will. Anyone who is a member of the site declares and undertakes that he has read and accepted the information about the usage contract and the processing of personal data in advance. In this context, all objections, lawsuits, complaints and claims regarding the processing of personal data are deemed to have been waived in advance.

3.2.2. Cases where personal data can be processed without explicit consent

3.2.2.1. Clear Foresight in Laws
Personal data of the data subject can be processed in accordance with the law without explicit consent, if clearly prescribed by law.

3.2.2.2. Failure to Obtain Clear Consent of the Concern Due to Actual Impossibility
The personal data of the data subject can be processed if it is necessary to process the personal data of the person who is unable to explain his consent due to actual impossibility or whose consent cannot be validated, or to protect the life or body integrity of another person.

3.2.2.3. Establishing the Contract or Being Directly Related to Its Execution
It is possible to process personal data if it is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract.

3.2.2.4. Legal Liability
If processing is mandatory for the Innly to fulfill its legal obligations, the personal data of the data subject will be processed.

3.2.2.5. Personal Data Owner to Publicize Personal Data
If the data subject has his personal data publicized, the relevant personal data can be processed.

3.2.2.6. Data Processing Is Necessary to Establish or Protect a Right
Personal data may be processed if data processing is mandatory for the establishment, use or protection of a right.

3.2.2.7.Innly's Legitimate Interest, Data Processing Is Necessary
Provided that the data processing is mandatory for Innly's legitimate interests, provided that it does not harm the fundamental rights and freedoms of the personal data owner, the personal data of the data owner can be processed.

3.3. Processing of Special Qualified Personal Data
Innly is sensitive to the regulations stipulated in KVK, in the processing of personal data determined as “special quality” with KVK.

In the 6th article of the KVK, certain personal data that are at risk of causing victimization or discrimination are defined as “special quality” when processed illegally. These data are; Data on race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, disguise and dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data.

In accordance with the KVK Law, by Innly; Personal data of special nature are processed in the following cases, provided that adequate measures are determined by the KVK Board:

If the personal data subject has explicit consent or
If the personal data subject does not have explicit consent; - Personal data of special nature, other than the health and sexual life of the personal data owner, when required by law,
Individuals or authorized institutions and organizations that are under the obligation of confidentiality for the purpose of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing, for personal data related to the personal and sexual life of the personal data owner. processed by.

3.4 Categorization of Personal Data
KVK Law based on one or more of the personal data processing conditions specified in Articles 5 and 6 of the KVK Law for the legitimate and legitimate personal data processing purposes by informing the relevant persons pursuant to Article 10 of the KVK Law ' Data are processed on the basis of data categories in accordance with the general principles specified in the KVK Law and all the obligations regulated in the KVK Law, in accordance with the principles stated in the 4th article regarding the processing of personal data.

3.5 Deletion, destruction or anonymization of personal data
Although it has been processed in accordance with the provisions of KVK Law and other relevant laws, in case the reasons requiring its processing disappear, personal data is deleted, destroyed or anonymized ex officio or upon the request of the person concerned.

3.6 Transfer of Personal Data
In line with the provisions of both the Constitution and the KVK law, Innly shows maximum care and attention in sharing personal data with domestic and / or abroad, and continues its activities in accordance with the current regulations.

ng Obligation
According to the Constitution, it is revealed that everyone has the right to be informed about personal data about him. Accordingly, in the 11th article of the KVK Law, "requesting information" is also considered among the rights of the personal data owner. In this context, Innly provides necessary information in case the personal data owner requests information in accordance with the 11th article of the Constitution and KVK Law.

In this context, in accordance with Article 10 of the KVK Law, personal data holders during the acquisition of personal data, Innly's identity during the acquisition of personal data, for what purpose the personal data will be processed, to whom and for what purpose the processed data can be transferred, personal data With the method and legal reason of collecting, it gives information about the rights that the personal data owner has within the scope of article 11 of the KVK Law. Every person who accepts the usage agreement on the site and who is a member of the site accepts that this lighting is made for him.

In addition, Innly provides information and transparency in personal data processing activities by announcing all the issues in KVK Law and personal data processing activities in accordance with the “Law and honesty” rule with various public documents, especially this Policy document.

4. Securing Personal Data
Innly pays utmost attention and care to ensure data security, and in this context, necessary precautions are taken regarding the following issues in order to ensure “data security” in accordance with Article 12 of the KVK Law.

I. Innly;

Prevention of personal data being processed unlawfully,
Preventing personal data from being illegally accessed,
It ensures that any necessary technical and administrative measures are taken to ensure the preservation of personal data, to ensure the appropriate level of security.

II. In case the personal data is processed by another natural or legal person on its behalf, Innly is jointly responsible for taking the measures mentioned in the first article together with these persons.

III. People who learn personal information due to Innly Legal personality, their employees and / or their duties cannot disclose such information in contradiction with the provisions of KVK law and other laws and cannot use them for purposes other than processing. This obligation continues after leaving office. IV. In the event that the processed personal data are obtained by others in illegal ways, it shall inform the concerned person as soon as possible.

5. Observing the Rights of the Data Owner
If the personal data owners submit their requests regarding their rights listed below to Innly, the requests are concluded free of charge as soon as possible and within thirty days at the latest. However, if the transaction requires a separate cost, the fee determined by the KVK Board or by other authorities will be charged by Innly.

In this context, data owners will be able to submit their requests to Innly in writing.

Personal data owners;

Learning whether personal data is processed,
If personal data is processed, requesting information about it,
Learning the purpose of processing personal data and whether they are used in accordance with its purpose,
To know the third parties to whom personal data are transferred domestically or abroad,
In the event that personal data are incomplete or incorrectly processed, to request their correction and to notify the third parties to whom the personal data is transferred,
Despite being processed in accordance with the provisions of the KVK Law and other relevant laws, requesting the deletion or destruction of personal data in case the reasons requiring its processing disappear and asking the third parties to whom the personal data has been transferred within this scope,
To object to the emergence of a result against the person by analyzing the processed data exclusively through automated systems,
In the event that the personal data is damaged due to the illegal processing of the data, it has the right to demand the removal of the damage.