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CONFIDENTIALITY STATEMENT

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1.  What Information Do We Collect?

We collect two kinds of information through our Website: The “Personally Identifiable Information” (“PII”) and Non-Personally Identifiable Information”(“Non-PII Information”). Personally Identifiable Information is information that identifies or can identify you as an individual (such as residence address, telephone number or billing information), and Non-Personally Identifiable Information is total information, demographic information, IP addresses and other information that does not directly reveal your identity.

Non-Personally Identifiable Information: When you visit or interact with our Website, third parties contracted by Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) in order to provide services to Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) may collect your Non-Personally Identifiable Information (for example, a catalog of the Website pages you visit). Non-Personally Identifiable Information is the information that is anonymous and does not personally identify you. Non-Personally Identifiable Information is generally collected from four different sources through our Website: Internet protocol addresses and web logs, cookies, pixel tags and other similar technologies, and any other Non-Personally Identifiable Information that you voluntarily provide to us as described below.

IP Protocol Addresses and Web Logs: The web servers of our Website automatically collect Internet Protocol (IP) addresses and log files of our Website visitors. Your IP address is a unique identification number that is automatically assigned to your computer by your Internet Service Provider (ISP). The number is automatically identified and stored in our server log files along with the time of your visit(s) and the page(s) you visit when you visit our Website. Such information is generally collected and does not contain any Personally Identifiable Information. We use the IP addresses of you and all users only for purposes of calculating the level of use of our Website, identifying the problems of Website servers, and administering the Website. Collecting IP addresses is a standard practice on the Internet and is performed automatically by many Websites. In addition to the Non-Personal use of the IP addresses described above, we may associate your Personally Identifiable Information with your IP address to prevent fraud and similar offenses.

Cookies: We and third party service providers may use a standard technology called “cookies” to collect information about how you use our Website. Cookies remain on your computer and help recognize your computer's browser as a known visitor to our Website. If you do not wish your information to be collected through the use of cookies, you must change your browser preferences to provide you with the choice of cookies. If you choose to decline cookies, you may not be able to use certain services of our Website (i.e. Services that require logging in to the Website).

Pixel Tags: We and our service providers may use pixel tags, web beacons, clear GIFs (hereinafter together referred to as “Pixel Tags”) or similar tools and HTML format e-mail messages in connection with the pages of our Website that monitor your use of our Website in order to provide you with more useful information and a more personalized experience on your next visit. A Pixel Tag is generally a single pixel (1x1) electronic image that the visitors of our Website normally do not see and that can be associated with the cookies on their hard disks. Pixel Tags do not contain Personally Identifiable Information and allow us to count users who visit certain pages of our Website to provide branded services and help us determine the effectiveness of our promotion or advertising campaigns. Pixel Tags, when used in HTML formatted e-mail messages, can notify the sender whether or not the e-mail has been opened.

2. How do we use the information we collect?

We know that protecting the information you share with us is crucial. We take necessary precautions in order to protect them against unauthorized access or disclosure. For example, only authorized staff has access to your personally identifiable information for limited reasons. Furthermore, we encrypt your credit card numbers and other sensitive information before you send such information from your computers to our computers. We also use firewalls to help prevent unauthorized access to your personally identifiable information.

You can rest assured when using our website. However, no system is completely secure. Even though we take all the necessary precautions to protect your information, there is always the possibility that you may be exposed. For this reason, you need to be very cautious while carrying or disclosing your personally identifiable information. For example, you should avoid sending your personally identifiable information via e-mail messages.

Non-Personally Identifiable Information: Non-Personally Identifiable Information cannot identify you personally; therefore, we may use this information for any purpose. For example, we may use such information to measure the visiting hours, the average time spent on our Website and the pages examined, and to diagnose problems on our servers and manage our Website, analyze and improve the features and functionality of our Website.

We also reserve the right to share such non-personally identifiable information that does not personally identify you with third parties for any purpose. We may also share this information for advertising purposes, or collectively, or for other purposes in other ways that will not disclose any Personally Identifiable Information of you with third parties who are not part of the Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”).

Personally Identifiable Information: Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) are responsible for the storage and security of personally identifiable information obtained about you. We would like to emphasize that your personally identifiable information cannot be used without your consent for any purpose other than for the purposes notified to you. However, if you do not wish to have your personally identifiable information shared, you should contact us at kvkk@rixos.com

Website: We may use the Personally Identifiable Information you provide to us to improve our Website based on your interests, to show the content you may be interested in, and to display the content according to your preferences.

Contact: If you prefer a pre-approved option, we may use your Personally Identifiable Information to provide you with information about Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) and their services and promotions on behalf of some of our partners. If you change your mind at a later time and no longer wish to receive these marketing communications from us, please see the “Pre-Approved Options Policy” below. You have the right to cancel and/or withdraw your approval at any time.

Administrative Matters: In case of any change in the Terms of Use of the Website and/or this Privacy Policy herein, Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) reserve the right to contact you or to inform you of any other administrative matters relating to our Website (i.e. Contacting to facilitate, complete or confirm a process).

Fulfilling the Requests: Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) may use your Personally Identifiable Information to fulfill your requests.

Facilitating the Processes: Forms on our Website may, from time to time, be filled with your Personally Identifiable Information to facilitate a process between you and Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”).

Special Business Purposes: We may also use your Personally Identifiable Information for advertising targeting, data analysis, audits, fraud prevention and other internal business purposes.

Purchasing/Commercial Services: When you make a purchase through our Website, we may collect your credit card number, billing address, and other information about this purchase (hereinafter referred together as “Payment Information”) from you. We will use the Payment Information you provide to issue an invoice to you for your purchase and to realize your purchasing transaction. By giving us your Payment Information, you authorize us to provide such information to third parties with your consent and as necessary to confirm and fulfill your order (i.e. to process your credit card number).

Share on social media: Our Website allows you to forward certain advertised events or hyperlinks to Website features to other people who you believe will be interested via e-mail messages or through Social Media.

Job Announcements: When you make a job application at Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) and submit your Personally Identifiable Information through our Website, such information will be used only to evaluate and process your job application. We may store your personally identifiable information for a period of time to evaluate your application for our current or future positions.

3. How is your Personally Identifiable Information Disclosed?

Communication with Affiliates: Commercial electronic messages within the scope of the agreement may be sent to you with your prior approval. As this approval can be obtained in writing or by any means of electronic communication, it is necessary for you to remove the check mark in the “sending electronic messages” part if you do not wish to receive commercial electronic messages within the scope of the agreement. You also have the right to refuse to receive commercial electronic messages at any time without providing any reason. However, if you provide contact information for the purpose of contacting you, we would like to state that approval for commercial electronic messages in relation to changes to and/or use of the services provided will not be obtained separately.

In addition, it is also legally possible to communicate for marketing, promotion and/or change services related to the same or similar services without your prior approval if your contact information has been obtained during the provision of the service and you have been informed of this type of communication and given the opportunity to refuse. However, you reserve the right to refuse such communication and to withdraw any approvals you have granted in this context, and you may inform us of such request via any means. If you choose to join in a pre-approved e-mail system, our affiliates may also send you announcements and notices of events, products or services that may be of interest to you. Please remember that you can withdraw your prior approval at any time. Please refer to the “Pre-Approved Options Policy” part below for additional information.

Other Purposes: We may also disclose your information in situations listed below: A court order or request for similar investigation, a request for cooperation from a government agency; to determine or enforce our legal rights; to defend against legal claims; or we may also share your Personally Identifiable Information, use or waive any rights or objections in other circumstances that are legally necessary.
We may disclose or share your Personally Identifiable Information in cases when we consider the disclosure to be appropriate in connection with efforts to investigate or perform illegal activities, suspected fraud or other misconduct or to perform other actions; or to protect and defend the rights, properties or safety of our company, users, employees or other persons; where we need to comply with the relevant law or cooperate with the law enforcement authority; or to enforce the terms and conditions of our Website or other agreements or policies.

4. Collection of Information by Third Parties

Third Party Advertisements: Advertisements on our Website are provided to you by our third party advertisement partners. Third parties advertising on our website may place a unique cookie on your browser or recognize it. Non-Personally Identifiable Information about your Website visits, such as the number of times you view an advertisement, may be used to provide you advertising service.

Third Party Hyperlinks: Our website may contain hyperlinks to third party websites that are not owned or operated by Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”). We insert these hyperlinks only for convenience. Inserting a hyperlink on our Website does not imply that the Website linked by Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) is secure and/or approved. If you provide Personally Identifiable Information to any such third party Website, your transaction will be processed by this third party's Website (and not https://www.rixos.com) and your Personally Identifiable Information will be collected by that third party and controlled by its privacy policy. Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) are not responsible for the privacy practices including these third-party Websites’ use of any Personally Identifiable Information you provide to them, or the content of these third-party Websites.

5. Use of Website by Minors:

The Website is not intended for individuals under thirteen (13) years of age and we do not require such individuals to provide Personally Identifiable Information through our Website. If a parent or guardian discovers that his or her child gave us Personally Identifiable Information without the consent of the parent or guardian (for example, by inputting an older age than the child’s actual age), such parent or guardian should contact us at kvkk@rixos.com. If Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) determine that they obtained the personally identifiable information of children under 13 years of age, they will immediately delete such information and accounts that are believed to be of minors under 13 years of age. Please refer to the Terms of Use for additional information on the use of Website by individuals who are not adults.

6. Accessing, Updating, or Deleting Information Collected about You:

Our Website also gives you the opportunity to delete or edit the Personally Identifiable Information you provided to us. In order to do so, you can click the ‘My Account’ tab and follow the instructions to change your Personally Identifiable Information on our Website. We will respond to your changes as soon as possible within the legal provisions provided that this information is in our databases. We would like to remind you that this information will remain on our Website even after you delete it, but only for our backup and archive files. If such information is not stored in our databases, we may not always be able to ensure that these corrections or deletions are done in other databases in a timely manner.

7. Safety of Personally Identifiable Information:

Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) take reasonable security precautions, including physical, electronic and operational precautions, that are consistent with industry practices, in order to ensure the security of and prevent unauthorized access to the Personally Identifiable Information collected through our Website. Even though Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) take all necessary precautions to protect the Personally Identifiable Information that is under their control, all transmittals of data or data storage types over the Internet cannot be guaranteed to be 100% secure. We do not take responsibility for any loss you may incur as a result of any interception, alteration or misuse of information during such transfers. Please contact us at kvkk@rixos.com if you have a reason to think the security of our Website is breached.

8. Online and Offline Practices:

Please do not forget that this Privacy Policy herein is applicable only for the online data collection and disclosure practices in relation to our Website and not applicable for any of our practices performed offline.

9. Contacting Fine Otel Turizm Isletmecilik A.S. and Ekopark Turizm Ins. San. ve Tic. Anonim Sirketi (“Company”) in relation to the Website:

In case you have a question in relation to this Policy or a different request, you may send such questions and/or requests via email to kvkk@rixos.com. Always remember that e-mail communications are not necessarily secure. For this reason, please do not share your credit card information and other sensitive information with us in your e-mail correspondences.

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