The Law on the Protection of Personal Data, which came into effect upon its publication in the Official Gazette on April 7, 2016 (the Law), stipulates that any information pertaining to identifiable or identifiable natural persons can only be processed in accordance with the conditions set forth in the Law. It includes regulations on the methods and scope of processing activities.

This Clarification Text (the Text) has been prepared in accordance with Article 10 of the Law titled 'Obligation to Inform of the Data Controller.' It includes important notifications about the processing of your personal data during the execution of the Management and Consulting Agreement with Homie Tourism and Trade Limited Company (Homie) and in order to fulfill mutual obligations arising from this contract.

The terms defined in this Text are:

Explicit Consent: Consent based on informed decision and expressed freely for a specific issue,

Anonymization: Making personal data unrelatable to an identifiable or identifiable real person, even when matched with other data,

Customer: A real person who has a Management and Consulting Agreement with Homie,

Relevant Person: A real person whose personal data is processed,

Personal Data: Any information relating to an identifiable or identifiable real person,

Processing of Personal Data: Operations performed on data such as acquiring, recording, storing, preserving, altering, rearranging, disclosing, transferring, taking over, making available, classifying, or blocking the use of personal data, entirely or partially by automatic means or by non-automatic means provided that it is a part of any data recording system,

Data Controller: The real or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.

Identity of the Data Controller

Homie Tourism and Trade Limited Company

Kuloğlu Mah. Turnacıbaşı Cad. No:30 D:2 Beyoğlu/İSTANBUL kvkk@homiesuites.com

Homie Tourism and Trade Limited Company, as the data controller, attaches great importance to the protection of your personal data and its processing in accordance with the relevant legislation."

Relevant Person, Personal Data, and Categories

Customer (Relevant Person)

Identity Information Data Contact Information Data Financial Data Other Data

Name-Surname, Turkish Identification Number                                   

Mobile Phone Number, Email Address, Address Information Bank Account Information

Information Related to the Property Subject to the Management and Consulting Agreement

Purposes for Processing Personal Data

When processing your personal data, compliance is ensured with the general principles stated in the second paragraph of Article 4 of the Law, which includes:

a) Being in accordance with the law and principles of honesty,

b) Being accurate and, when necessary, up to date,

c) Being processed for specified, explicit, and legitimate purposes,

d) Being related to, limited to, and proportionate with the purposes for which they are processed.

Actions are taken within the framework of procedures and principles stipulated in the Law. Additionally, your personal data can be processed without your explicit consent only in the presence of one of the conditions listed in the second paragraph of Article 5 of the Law, which includes:

a) Being clearly foreseen by laws,

b) Being necessary to protect the life or physical integrity of the person who is physically or legally incapable of giving consent,

c) Being necessary for the processing of personal data of the parties of a contract, provided that it is directly related to the establishment or execution of the contract,

d) Being necessary for compliance with a legal obligation of the data controller,

e) The relevant person having made the data public,

f) Data processing being necessary for the establishment, exercise, or protection of any right,

g) Data processing being necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person.

Your personal data will be processed by the data controller only with your explicit consent if none of the above conditions are met.

Homie will process your personal data for the following purposes, within the legal limits described above and under appropriate conditions.

Customer (Relevant Person)

Execution of emergency management processes.

Execution of information and transaction security processes.

Conducting communication activities with the customer.

Ensuring that activities are conducted in accordance with legislative provisions.

Monitoring and execution of legal affairs.

Conducting storage and archiving activities.

Providing information to authorized persons, institutions, and organizations.

Fulfillment of legal obligations in accordance with the Management and Consulting Agreement.

Identity Information Data Contact Information Data Financial Data Other Data"

Who Personal Data Can Be Transferred To and For What Purposes

Homie can transfer the properly collected personal data to real or legal persons located domestically and internationally - as specified in the paragraph below - by fulfilling the necessary procedures set forth in Article 8 of the Law and by ensuring the prescribed security measures.

Additionally, data transfers can be made with the US-based Google and Microsoft for the purposes of conducting business activities, supervision, information processing, and communication through electronic channels, which provide email services.

Affiliates and Subsidiaries

(İmtihan Tourism and Trade Joint Stock Company)

Execution of information and transaction security processes.

Conducting communication activities with the customer.

Planning and execution of business processes.

Providing information to authorized persons, institutions, and organizations.

Conducting management activities.

Suppliers

Authorized Public Institutions and Organizations

Execution of information and transaction security processes.

Conducting communication activities with the customer.

Conducting storage and archiving activities.

Ensuring that activities are conducted in accordance with legislative provisions.

Monitoring and execution of legal affairs.

Providing information to authorized persons, institutions, and organizations.

The text provided is a detailed legal document in Turkish regarding the methods and legal reasons for the collection of personal data, as well as the rights of the individual (the "Relevant Person") under the law. Here's the translation to English:

"Methods of Collection of Personal Data and Legal Reasons

Your personal data are collected automatically or by non-automatic means depending on the needs that may arise during the term of the Management and Consulting Agreement executed between you and Homie. Your personal data can be collected:

During the execution of the Management and Consulting Agreement, when filling out the necessary information for the agreement to be executed, and

Throughout the duration of the said agreement, by mutually sharing the information that is mandatory to fulfill the obligations arising from the Management and Consulting Agreement.

Your personal data are processed within the framework of the purposes specified in Article 3 and according to the legal reasons set forth in Articles 5 and 6 of the Law.

Identity Information Data

Necessary for the processing of your personal data, provided that it is directly related to the establishment or performance of the Management and Consulting Agreement established between you and Homie.

Your personal data having been made public by you.

Necessary for the processing of your personal data in order for Homie to fulfill its legal obligations.

Contact Information Data

Necessary for the processing of your personal data, provided that it is directly related to the establishment or performance of the Management and Consulting Agreement established between you and Homie.

Your personal data having been made public by you.

Financial Data

Necessary for the processing of your personal data, provided that it is directly related to the establishment or performance of the Management and Consulting Agreement established between you and Homie.

Your personal data having been made public by you.

Duration of Processing Personal Data

Your personal data will be preserved in accordance with the Law and stored with the necessary security measures. If the Management and Consulting Agreement, which is the primary legal reason for the processing of your personal data, is terminated, your personal data will be deleted, destroyed, or anonymized by us after the periods designed to prevent the birth or use of a right such as statute of limitations or similar are over, as foreseen by the legislation. The deletion, destruction, or anonymization of your personal data will be carried out within the framework of the Regulation on the Deletion, Destruction or Anonymization of Personal Data, which is issued under Article 7 of the Law.

Rights of the Relevant Person under Article 11 of the Law

Article 11 of the Law is as follows; "Everyone, by applying to the data controller, can:

a) Learn whether personal data is processed,

b) Request information if their personal data has been processed,

c) Learn the purpose of data processing and whether personal data are used in accordance with its purpose,

d) Know the third parties to whom personal data is transferred domestically or internationally,

e) Request the rectification of incomplete or inaccurate data, if any,

f) Request the deletion or destruction of personal data within the conditions set forth in Article 7,

g) Request notification of the actions taken in compliance with subparagraphs (d) and (e) to third parties to whom personal data has been transferred,

h) Object to an outcome that is to the detriment of the individual through analysis of personal data exclusively by automated systems,

i) Request compensation for the damage arising from the unlawful processing of personal data.

Homie, as the data controller, has organized certain application channels to enable the Relevant Person to exercise their legal rights listed in Article 11 of the Law. You can convey your requests to Homie in the manner specified in the table below. Requests must be sent by filling out the form located at https://www.homiesuites.com/kvkk-ilgili-kisi-basvuru-formu. If the application form on the link is not used, the request of the data owner Relevant Person must necessarily include;

Name, surname and wet signature if the application is made in writing,

In applications made via email, if the email address to which the application form will be sent is not registered in Homie's systems, the application form must be signed with a mobile or electronic signature,

Turkish Republic identity number