KALE PRIVACY POLICY |
|
Last Revision Date: [ * ] October 2020 We, Kale Kilit ve Kalıp Sanayi Anonim Şirketi (“KALE”), undertake to protect your privacy. This Privacy Policy describes how we collect, use, disclose and protect your Personal Information under the Kale BLE Mobile Key Application which is our Hotel Management Software. In this document, our online activities for Kale BLE Mobile Key Application shall be referred to as "Application" and offline activities "Services". You are required to create an account by signing up to the Application in order to access the Application and the Services offered through the Application. To offer better service for you and to improve the services of KALE or other cases for which you consented, you may access the other services offered by KALE through this account you have created. The term "we", "us" and "our" contained in this Privacy Policy shall refer to KALE which is deemed the data controller. For further information about us or our brands please visit https://www.kalekilit.com.tr/tr. "Personal Information" refers to any information about any identified or identifiable real person. This has broader meaning than that of personal or sensitive information, and includes information such as your name, date of birth, and email address. Our Privacy Policy Guide Headings 1. Scope of the Privacy Policy 2. Your Consent 3. How we collect your Personal Information? 4. For what purposes can we use your Personal Information? 5. With whom can we share your Personal Information? 6. How do we protect your Personal Information? 7. Your direct marketing choices 8. How can you access, correct or delete your Personal Information? 9. How long do we retain your Personal Information? 10. Children 11. Transfer to the other countries 12. Changes to the Privacy Policy 13. How can you contact us? Our Privacy Policy Guide Details 1. Scope of the Privacy Policy Our Privacy Policy shall apply to all the Personal Information that we collect, use, share or otherwise process through our both online and offline activities that point, link or refer to this Privacy Policy. These activities also include: our mobile applications our official social media pages our emails our online and offline campaigns your meetings or correspondences with our representatives. Please note that the Application may include a hyperlink to third party websites, applications, etc., which are not controlled by us and do not fall under this Privacy Policy. We do not assume any responsibility and obligation regarding the content and activities of such third-party websites, applications and the like. We do recommend you to read the privacy policy of such third parties regarding how they use your Personal Information as such third parties may collect your Personal Information. 2. Your Consent In many cases, we will ask your explicit consent in order to process your Personal Information for a specific purpose, however, by downloading the Application you consent the processing of your Personal Information as described in this Privacy Policy. We collect, use, disclose and process your Personal Information fairly and in legal circumstances. 3. How we collect your Personal Information? The personal information directly collected from you First, we may collect your personal information directly from you, for example, when you sign up for our newsletters, register in the Application, buy a product from us, fill out a survey, make a comment or ask a question, post something on our social media pages, etc The Personal Information collected in this way may include: name address email address phone number age date of birth gender product purchase and usage details Location details of the device accessing the application, household details User-generated content, messages and other content that you have uploaded to the application other Personal Information that you directly furnish us. Personal Information automatically collected Secondly, certain Personal Information may be automatically collected when you visit or use the Application, for example, such information collected through the Application by cookies and other technologies Information regarding the type of your (mobile) device or browser; Information about how you use the application, for example, such as the details of the web pages you view, banners you click and hyperlinks; whether you read the emails we sent; your IP address; Information you opt to share by using the social media tools placed on the Application; Your exact location data if you have consented. Personal Information collected from other sources Personal Information collected in this way may contain income level, interests such as hobbies and pets, consumer and market research data, buying behavior, publicly disclosed data or actions such as blogs, videos, internet posts and user-generated content. 4. For what purposes can we use your Personal Information? We may use your Personal Information for business purposes as indicated below: To ensure the correct and effective operation of the application; to provide you with an opportunity to participate in promotions, contests, surveys and voting; to provide you with an opportunity to share information and ideas on our social media pages, forums, blogs and other communication channels and to participate in social sharing via the Application or websites of our trusted business associates to understand your needs better and thereby provide you with the more appropriate information, to analyze and assess our corporate activities, to develop new products and improve our existing products and services, to conduct market researches and audits, to determine user tendencies and to examine the effectiveness of our marketing campaigns and the satisfaction of our customers; to tell you about our products and services, and to share with you promotional materials regarding our brands and our carefully selected trusted business associates (for example, announcements about new products, promotions, savings programs, joint promotions, and our other programs); To harmonize your past activities on the Application with the experience and content of the Application in order to manage the Application and personalize your experience here; to respond to your requests or questions. We would like to particularly emphasize that we do not sell your Personal Information. We may create anonymized data records from your Personal Information excluding the information that is personally identifiable with you (for example the information such as your name). We use such anonymized data to analyze our products and services. We reserve the right to use such anonymized data for any purposes at our sole discretion and to disclose them to the third parties including but not limited to our research partners. 5. With whom can we share your Personal Information? Intra-group sharing Your Personal Information may be shared between the different companies and brands of our group, for the purposes set out in this Privacy Policy. Third party service providers We may share your Personal Information with trusted third-party service providers who work on our behalf, such as marketing agencies, market research companies, e-commerce business partners, software providers, merchants selling our products, call centers, payment processors, etc. These third-party service providers are required not to use your Personal Information other than to provide the services you requested from us. Acquisitions If another company acquires our company, business, or our assets (or a part thereof) may acquire all or part of the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy. Requited Disclosures We may disclose your Personal Information if we believe in good faith that such disclosure is necessary in the following cases: in connection with any legal investigation; to comply with relevant laws or to respond to court orders, summons or warrants served on us; to protect or defend our rights; to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or any applicable Terms of Use. 6. How do we protect your Personal Information? We have implemented appropriate technical and structural measures to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access and against all other unlawful forms of processing. The Personal Information you provide us is stored on computer systems which are located in controlled facilities which can only be accessed by a limited number of persons who have a need to know in order to carry out their tasks and any services requested by you. 7. Your direct marketing choices We may periodically send you free newsletters, surveys, offers, and other promotional materials related to our products and services which we believe that they are useful for you, if you have consented via e-mail or any other electronic channel. If you do not wish to receive such communications anymore, you will always have the opportunity to "opt out" by following the unsubscribe instructions provided in each of our direct marketing e-mails or in other electronic communications such as SMS or by contacting us directly (at the contact details below). Despite your email preferences, we may send you the update notifications to our Privacy Policy. 8. How can you access, correct or delete your Personal Information? We intend to keep your Personal Information accurate and up-to-date. We offer you an opportunity to reasonable access your Personal Information, to make a request for the correction and erasure them as appropriate. We implement reasonable measures to protect your privacy and to validate your identity before granting access to your Personal Information. To get information about and make changes on your Personal Information, you can follow the instructions on the Application or reach us at [+90 ***********]. By applying us: - You may receive information about whether any of your Personal Information has been processed by us; - You may receive information about the purpose of the processing of your Personal Data and whether it is used for its intended purpose; - You may receive information as to the third parties to whom your Personal Information is transferred at home or abroad; - You may request the rectification, deletion or destruction of the Personal Information in case it is incomplete or inaccurate; - You may request that the rectification, deletion or destruction of your Personal Information are notified to the third parties to whom your Personal Information is transferred; - You may appeal to the negative results against himself/herself arising from the processing of your Personal Information exclusively through the automatic systems; and - You may request compensation for the damages in case you incur any damages due to the unlawful processing of your Personal Information. We will respond to your requests within a reasonable time and in accordance with the rules specified in the applicable legislation. 9. How long do we retain your Personal Information? We will only retain your Personal Information as long as reasonably required for the above-mentioned purposes. 10. Children The Application is not for children and we kindly request that the children under the age of 12 do not provide their Personal Information through the Application. If you are the parent or legal guardian of a child under 12 who has registered on the Application, or who has otherwise provided Personal Information to us, please contact us at [ +90 ***********] to have the information deleted. Information voluntarily provided by children via e-mails, message boards, chat sessions etc. may be used by other parties to generate unsolicited e-mails. We encourage parents and legal guardians to inform children about how to use the Internet in a safe and responsible manner. 11. Changes to the Privacy Policy We may update this Privacy Policy from time to time. In case of any update, the date appearing on the top of this Privacy Policy will be updated accordingly. In case of any material change to our Privacy Policy which substantially changes our privacy practices, we may notify you in advance about the update to be made in other ways before the changes become effective; for example, this would be through the last e-mail address you provided us or in the form of a notification on our corporate website and/or social media page. Please always verify whether you have consulted the latest version of the Privacy Policy. If you continue to use our Application and Services, then you will be deemed to have agreed on this Privacy Policy and all updates thereof. 12. How to contact us? We welcome your comments and inquiries regarding this Privacy Policy or our processing your Personal Data. You can contact us at [ +90 *********** ] or via the email address [**********] . |