1. Processing of Personal Data
General Principles — swandorhotels.com acts in accordance with the general principles set out in Article 4 of the Law when processing personal data obtained through the website and mobile application: compliance with the law and honesty rules; being accurate and up to date when necessary; processing for specific, explicit and legitimate purposes; being relevant, limited and proportionate to the purpose of processing; and retention only for the period required by legislation or the purpose of processing.
Purposes of Processing — Your personal data is processed for hotel reservation transactions (completing and managing your reservation, confirmations, cancellations, and reminders); for contact purposes (responding to your requests and sending relevant messages); to fulfil legal obligations (retention, transfer, and disclosure where required by law or requested by administrative or judicial authorities); and to improve our services and customer satisfaction (analytics, handling requests and complaints, and publishing guest reviews where you choose to share them).
2. Legal Grounds and Collection of Personal Data
swandorhotels.com may collect personal data electronically through our call centre and email channels, reservation forms on our website and mobile application, membership registration forms, live support panels, web analysis tools, and cookies. We also collect personal data when a User discloses it directly by contacting us through other means.
Transfer of Personal Data — We share personal data only to the extent necessary and in accordance with the law; we do not transfer or sell it for commercial purposes to third parties. Personal data of Users who make a reservation is shared with the relevant accommodation facility, in Turkey or abroad, to complete and manage that reservation. Personal data may also be shared with our business partners and external service suppliers under the conditions of Articles 8 and 9 of the Law, and, where consent has been given, with solution partners carrying out marketing, profiling, and advertising activities on our behalf.
Deletion, Destruction and Anonymisation — Personal data is stored for the periods stipulated by relevant legislation and/or required for the purpose of processing. Once this period expires, personal data is destroyed in accordance with the Law and the Regulation on Deletion, Destruction or Anonymisation of Personal Data.
3. Data Security
swandorhotels.com takes all appropriate technical and administrative measures to ensure personal data is processed in accordance with the law, and to mitigate risks such as malicious use, unauthorised access, sharing, destruction, or alteration of personal data.
4. Web Monitoring & Cookies
Our website and mobile application collect and store data for analysis, marketing, and optimisation purposes using Google Analytics, Hotjar Ltd., and NextRoll, Inc. web tracking technologies. Detailed information on web tracking can be found in the respective privacy policies of Google, Hotjar, and NextRoll.
5. Social Media Plugins
Various social media plugins are integrated into our website and mobile application. By clicking an integrated social media button, some of your information may be shared with that provider. If you are logged in to a social media account, or social media cookies are stored in your browser, the provider may recognise your visit and associate it with your profile. To prevent this, log out of your social accounts before visiting our website, and review the privacy policies of Facebook, Twitter, Google/YouTube, Pinterest, Instagram, LinkedIn, and NextRoll for more information.
6. Rights of the User
By contacting swandorhotels.com as the data subject, you have the right to: learn whether your personal data is being processed; request information about processed personal data; learn the purpose of processing and whether it is used accordingly; know the third parties to whom your data is transferred; request correction of incomplete or inaccurate data; request deletion or destruction of your data once the reason for processing no longer applies; object to a result produced solely through automated analysis of your data; and request compensation for damage arising from unlawful processing of your data.
If you submit a request regarding these rights in accordance with the applicable application procedures, swandorhotels.com will respond free of charge, as soon as possible and within 30 days at the latest. If the request requires an additional cost, a fee may be charged in line with the tariff determined by the Personal Data Protection Board.
7. Changes to This Privacy Policy
swandorhotels.com may amend this Privacy Policy at any time. Changes become effective on the day the updated Privacy Policy is published, and we will inform Users of any material changes.
8. Contact
You can send your questions and requests regarding this Privacy Policy to swandorhotels.com through our official contact channels.