WEB SITE DISCLOSURE TEXT

At Lucis Global Turistik Yatırımlar ve İşletmecilik Ticaret Anonim Şirketi (Avantgarde Hotel) we use cookies to ensure the functionality of the website and to provide you with a better experience when visiting our websites. As “Data Controller” within the meaning of Law No. 6698 on the Protection of Personal Data, we take care to comply with our obligations regarding your personal data when using these technologies.

This disclosure text was drafted in accordance with the “AVANGARDE OTEL Dış Ticaret Anonim Şirketi - Data Policy” to inform you about the collection and processing of personal data of visitors through cookies on the websites of Avantgarde Hotel. In the event that the cookies on the website are removed, renewed or increased in number and new technological options other than cookies are used, this text shall also be updated.

I. YOUR PERSONAL DATA COLLECTED

At Avantgarde Hotel, we collect data from website visitors through cookies.

II. PURPOSES OF PROCESSING YOUR PERSONAL DATA

Avantgarde Hotel processes the data obtained through cookies for the following purposes;

To perform the basic functions necessary for the proper functioning of the Website,
To analyze visitors’ activities on the website in order to improve the website’s performance,
To make the visit to the website more pleasant.

If the purpose of the processing of personal data obtained through the Website changes or a new purpose is added, Hotel Avantgarde shall fulfill its obligation to inform you without delay before starting the processing of data for this purpose.

III. METHOD AND LEGAL BASIS FOR THE COLLECTION OF YOUR PERSONAL DATA

Avantgarde Hotel obtains the personal data of the website visitors electronically, in digital format (visitor entry-exit log, numerical data), by fully automatic methods in order to achieve the above-mentioned purposes.

Avantgarde Hotel processes your personal data for the following legal reasons:

Presence of an explicit consent given by you,
The processing is strictly necessary for the data controller to fulfill its legal obligations,
The processing is strictly necessary for the legitimate interests of the data controller, provided that it does not adversely affect the fundamental rights and freedoms of the website visitor.

Avantgarde Hotel uses the following cookies on its website:

ASP.NET_SessionId	Platform session cookie for general purposes used by websites written with Miscrosoft .NET-based technologies. It is usually used by the server to maintain an anonymous user session. It is a cookie that manages the website visitor’s session without obtaining personal data.
_ga	It is associated with Google Universal Analytics, an important update of Google’s widely used analytics service. It is used to distinguish unique users by assigning a randomly generated number as a customer identifier. It is included in every page request on a website and is used to calculate visitor, session and campaign data for website analytics reports. It helps to distinguish visitors from each other.
_gat	It is linked to Google Universal Analytics and, according to the documentation, is used to reduce the request rate and thus limit data collection on high-traffic websites. It is a cookie used to limit the number of requests sent to Google Analytics.
_gid	It is set by Google Analytics. It stores and updates a unique value for each page visited and is used to count and track page views. It is a cookie that is used to distinguish visitors from each other.
YSC	Set by YouTube to track views of embedded videos.
_fbp	It is used by Meta to deliver a number of advertising products, such as real-time bids from third-party vendors.
IDE	Set by Doubleclick to provide information about how the end user uses the website and what ads the end user may have seen before visiting that website.
VISITOR_INFO1_LIVE	This variable is set by Youtube to track user preferences for Youtube videos embedded in websites; it can also determine whether the website visitor is using a new or old version of the Youtube interface.
_gcl_au	Used by Google AdSense to test the effectiveness of advertising on websites that use their services.
test_cookie	Set by DoubleClick (owned by Google) to determine if the website visitor’s browser supports cookies.

IV. PERSONS TO WHOM PERSONAL DATA MAY BE TRANSFERRED AND THE PURPOSES OF THE TRANSFER

Hotel Avantgarde assures visitors to the Website that it shall comply with the provisions and principles of the Personal Data Protection Act, the decisions and regulations of the Data Protection Authority and other laws regarding the transmission of your personal data.

In this context, Avantgarde Hotel shall not disclose your personal data to other real or legal persons residing in Turkey or abroad, unless you have given your express consent.

However, in one of the following exceptional circumstances, your personal data may be transferred without your express consent.

The processing of the data is absolutely necessary for the legitimate interests of Avantgarde Hotel, provided that the fundamental rights and freedoms of the visitor to the website are not thereby impaired.

In the event of one of the exceptional circumstances mentioned above, the transfer of your personal data abroad without your express consent is only permitted in the country to which the personal data is transferred if;

There is adequate protection (countries with adequate protection are determined and announced by the Council for the Protection of Personal Data).
If adequate protection does not exist, the data controllers in Turkey and in the country concerned shall undertake in writing to ensure adequate protection and the Data Protection Board shall authorize the transfer.

Avantgarde Hotel may transfer your personal data to the following categories of recipients within the scope of the processing purposes specified in Article II of this Disclosure Text and to the extent necessary for those purposes:

- Natural persons or legal entities under private law, shareholders, suppliers, group companies, authorized public bodies and organizations.

V. YOUR RIGHTS UNDER THE LAW ON THE PROTECTION OF PERSONAL DATA

In relation to your personal data collected and processed by Avantgarde Hotel, you may exercise your rights under Article 11 of the Law No. 6698 on the Protection of Personal Data in accordance with the “Communiqué on the Procedures and Principles of Application to the Data Controller”.

To exercise your rights under the Law No. 6698 on the Protection of Personal Data

fill out the “Data Subject Application Form Pursuant to the Law on the Protection of Personal Data” document on www.avantgardecollection.com in digital form or pick one in hard copy at the company’s workplaces;

You can submit it with your signature in person at the company’s workplaces or through your proxy with a special power of attorney.
You can send it through a notary public.
You can send it to our company’s [email protected] address from your own Registered Electronic Mail (KEP) address with the subject line “Information Request within the Scope of the Law on the Protection of Personal Data”.
Sign with your secure electronic signature or mobile signature and send it in a digital format to [email protected] with the subject line “Information Request within the Scope of the Law on the Protection of Personal Data”.
You can send an e-mail to [email protected] from your e-mail address previously notified to our company by you and registered in our system, with the subject line “Information Request within the Scope of the Law on the Protection of Personal Data”.
You can send it to us by filling out our online KVKK application form at www.avantgardecollection.com.

Avantgarde Hotel shall process the requests in the application free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff determined by the board may be charged.

To access the data controller application form, click here.