CLARIFICATION TEXT

A. The Policy of Protecting and Processing the Personal Data

As being ‘As Beton İnş Taah Gıda Turz San ve Tic Aş’(Arcanus Hotels Trendline Side), we show maximum sensitivity to the subject of the security of your personal data. With this consciousness, as Company, we pay enormous attention to the protection and processing of all kinds of data belonging to all individuals that have relationships with the Company, including the individuals that utilize our products and services in accordance with the Law on the Protection of the Personal data numbered 6698 (KVK Law). With full comprehension of our responsibility, and with the status of “Data Responsible” as defined in KVK Law, we process your personal data as explained below within the boundaries ordered by the legislations.

The protection of the personal data is among the basic policies of our Company and our Company has always paid attention to the confidentiality of the personal data during its presence and adapted this as a working principle and instructed its employees to work in direction with this principle. Our Company accepts and pledges to conform to all responsibilities brought by the KVK Law. With full consciousness of our responsibility and with the status of being the Data Responsible, we process, save, transfer, share and keep your personal data as we explain below and within the boundaries ordered by the official legislations.

For your questions regarding the “Disclosure Text regarding the Processing of the Personal Data” of our Companies, you can contact us by using the following contact information:

Application Address: Sorgun Mahallesi, Acısu Mevkii, 07600 Manavgat/Antalya

Application E-mail : kvkk@arcanushotels.com

Our Company reserves its right to always update hereby this “Disclosure Text regarding the Protection of the Personal Data” within the boundaries of changes that can be made in the current legislations.

B. The Collection, Processing of the Personal Data and the Purposes of Processing:

The Policy of Our Company regarding the Protection and Confidentiality of the Personal data is prepared in conformity with the KVK Law. Within this boundaries, your personal data can change according to the services, products or commercial activities provided by our Company and can be collected with automatic or non-automatic methods and with mediums such as offices, branches, vendors, call centers, internet web-sites, social media channels, mobile applications and similar as oral, written or electronically. As long as you utilize the products and services of our Company, your personal data can be processed by establishing and updating.

Besides, with the intention of utilizing the products and services of our Company, your personal data can be processed;

a. When you use our call center or web-site,

b. When you visit our Company, facilities, units,

c. When you visit our internet web-sites or social media channels/environments,

d. When you attend to trainings, seminars or organizations arranged by our Company,

Your personal data that are acquired with the required reasons of legal conformity stated in the laws of the Republic of Turkey, within the conditions and purposes of personal data processing stated in the 5th and 6th Articles of the KVK Law by our Company and the related Companies/institutions and the real persons and/or legal entities stated in the (E) clause below, all with the purposes as stated below:

a. For our work units to carry out the required works to make you to utilize the products and services that are offered by our Company.

b. Offering and presenting you the products and services that is offered by our Company by personalizing according to your using habits and needs.

c. To increase the quality of the services offered by our Company and to improve our quality policy.

d. To inform and make you utilize our general and special campaigns, promotion, introduction, discount and similar advantages.

e. In order to provide you the products and services you requested, being able to process your personal data composed of your name and password that you entered to the platforms that are offered by our Company with the purposes of receiving services, including the acquired data with your personal data, choices, processes, the time of your visit in these platforms.

f. Being able to make you notifications related to all kinds of cards (Wydham Rewards) that are issued or will be issued by our Company and the related companies/institutions and about the web-site memberships to our Company and the related companies/institutions (renewal, terminating, etc.), informing you regarding the new products and services offered and the possible changes and renewals in the personal data policies and membership conditions, and similar issues with all kinds of information that can provided to you.

g. Providing the legal and financial security of our Company and the individuals that are in business relationship with our Company (administrative operations towards communication, to provide the physical security and audit of the locations of our Company, the evaluation processes of the business partner/customer/supplier (authorized ones or the employees), legal conformity process, financial works, etc.)

h. Managing the security operations, accidents or other similar events with purposes of medical-insurance.

i. Making marketing research and research and development studies and besides developing and improving our product range, services, shops, information technology systems and security systems.

j. By utilizing the video camera records (CCTV), providing security to people in our facilities and preventing the crimes that require punishment and helping their detection and prosecution; also by considering the photographs, building your legal rights, implement or defense them.

k. Informing you regarding the information you request, events and services.

l. Specifying and implementing the commercial and business strategies of our Company.

m. For enabling the implementation of the human resources policies of our Company.

n. When overtly stated in the legislations or when required, conducting a legal liability.

C. The Method and Legal Purpose of the Personal Data Collection:

Your personal data is acquired in various oral, written or electronic environments and for the purposes stated above and for our Company to offer products and services in specified legal framework and in this respect for our Company to fulfill its responsibilities completely and correctly that have arisen from the agreement and the law.

Your personal data that are collected with this legal purpose are processed, saved, transferred, shared and kept with the purposes stated in the B clause of this text within the personal data processing conditions stated in the 5th and 6th Articles of the KVK Law.

Processing in accordance with law and the Rules of Honesty

While processing the personal data, our Company acts in accordance with the principles brought by the legal regulations and the rule of honesty.

Accuracy and the up-to-date data

When the data is now known to our Company as it has processed by considering the basic rights and its legitimate benefits within the context of the KVK Law and the relevant legislations, then our Company maintains their up-to-datedness.

Processing with Specific, Overt and Legitimate Purposes

Our Company processes the personal data that would be convenient to realize the previously determined purposes and avoids processing the data not needed and not related to realize the purposes. In this respect, processing of the data is limited with the activities and legal liabilities. The additions to the purpose can be in moderate levels and by providing reasons.

Being Moderate and Limited and connected with the Purposes

For realizing the purposes determined by our Company, the personal data is processed within the framework of the legal and legitimate benefits; personal data activities that do not include any legal and legitimate benefits and that are not for the purposes, are not implemented.

Keeping the data as required for the processing purposes or as stipulated by the legislations

Our Company keeps the personal data for a period specified in the relevant legislation and other laws and for a period that is necessary for the required periods. They are processed for a period required by the customs of the commercial life and the applications of our Company.

If the processing purposes are ended and the period stated in the relevant legislation and it is time for the company, the personal data can be kept to be potential evidences in possible legal disputes to provide the defense or a right claim. In such a case, the data kept cannot be reached for other purposes and can be just accessed to be used in such legal disputes.

Confidentiality Policy

The web-site that you are about to visit, belongs to the Company and managed by the Company. By using our web-site, you give consent for your personal data to be used that is acquired and collected by our web-site.

Our Company pledges to provide your confidentiality. This policy is valid just for this web-site and not valid for the web-site owned by the third persons. By using our web-site, if you do not accept the current conditions of our Confidentiality policy that is announced in the area of this site, please do not share your personal data in this web-site.

When you don’t share your personal data with your explicit consent, we confirm that our Company will not collect any data from your visits to our web-site. When you share your personal data, you give authorization to us to use this information in direction with the conditions of the Confidentiality Policy.

The personal data you can share are used for the following purposes:

• Sending Newsletters or notifications

• Sending written publications or other correspondences

• Delivering the products you have bought or your awards

• Processing your reservation requests and managing your account

• Calculating the statistics regarding your operations

• Building commercial statistics and analysis about web-site usage

In this web-site, when you prefer not sharing your personal data, you will not utilize some rights such as accessing some parts of the web-site, requesting online newsletter, making online reservation, making application, giving feedback about our businesses or sending us emails.

Cookies are small data files that enable our web-site to collect and store a range of data from your laptop, computer or mobile phone. Companies can use ‘cookies’ to collect information such as the special web-sites you visit and the services you utilize in our web-site. We collect this information to change our web-site and the products that you are interested and you need. When you visit our web-site again, these ‘cookies’ can be used to make your operations more quickly.

For example, our web-site can recognize some private information you give in order to avoid asking you the same questions again. Browsers are often adjusted in advance to accept cookies. Preferably, you can adjust your browser to reject or to be notified when ‘cookies’ are sent. When you reject ‘cookies’, this can prevent your browsing through some parts of the web-site or your private information to be taken when you visit web-site.

By specifying when you entered our web-site, which pages you visited and how long you stayed there, we can measure the effectiveness of the presence of our web-site. Web-site measuring statistics can be used for personalizing the web-site experience and also establishing statistics about our web-site usage and its evaluation.

Some data regarding your computer can also be collected such as your IP address (the number specified for your computer when you use internet), your browser and your operating system and these can be connected to your personal data. This is required for our web-site to offer best experience to our visitors and to be one of the most effective information sources.

We take reasonable precautions to provide the security of your personal data. All personal data that can be detected are subject to limited access in order to prevent unauthorized access, alteration and improper use.

The institutions that provide services to the Company shall also keep the relevant information as confidential and shall not let this information to be used apart from the stated purposes regarding the services provided for the Company.

D. Processing of the Sensitive Personal Data:

At the 6th Article of the KVK Law, some personal data are specified as “sensitive” which have risks of causing discrimination or unjust treatment of the individuals when the data is processed. These data are as follows: nationality, ethnical background, political view, philosophical belief, religion, sect or other beliefs, clothing and appearance, membership to foundations, associations or unions, health, sexual life, criminal convictions and the data regarding the security precautions and the biometric and genetic data.

Our Company acts in conformity with the regulations stipulated in the 6th Article of the KVK Law in terms of the processing of the personal data and acts with sensitivity towards their protection.

a. If the personal data owner has explicit consent;

Our guests can share their current conditions with our Company and can request personalized service and can share their sensitive information with this purpose (when our guest share their sensitive personal data and request special service; For example requesting thin pillow because of her/his problem in her/his neck, requesting to have a room in the first floor because of her/his heart problem, requesting desserts without peanuts because of her/his allergy). Our Company will process sensitive data from such guests just for the purposes of data collection and only by taking their explicit consent in order to offer them personalized service according to their needs that they have defined by sharing their sensitive personal data.

b. When the data owner has no explicit consent;

• Sensitive Personal Data apart from the relevant person’s health and sexual life, in the conditions stipulated by the law;

• Sensitive Personal Data regarding the relevant person’s health and sexual life can only be processed for the purposes of the protection of the public health, protective medical profession, medical diagnosis, execution of the treatment and care services, planning of the health services and their financing and management, by the individuals and authorized institutions and establishments and all under the liability of keeping the confidential information as secret.

E. To whom and with what purposes the processed personal data can be processed:

Your collected personal data can be transferred to our shareholders, business partners, suppliers, legally authorized public institutions and private persons for the purposes stated in B Clause, and within the framework of the purposes and personal data processing conditions specified in the 8th and 9th Articles of the KVK Law.

F. Transfer of the personal data to abroad:

Our Company has authorization to transfer the personal data to abroad within the conditions specified by the KVK Board on The Protection of the Personal Data as stipulated in KVK Law and by conforming to other conditions in the law and after getting the explicit consent of the individual.

G. The right of the individual stipulated in the 11th Article of the KVK Law:

We accept that the guests have rights that before processing, saving, transferring, sharing and keeping their personal data, their consent shall be taken and disclosure text shall be provided and after the processing, saving, transferring, sharing and saving their data, they can determine the destiny of their data. Within this framework, as personal data owners, when you deliver your request regarding your rights with the methods stated in hereby this “Disclosure Text regarding the Processing of the Personal Data”, our Company will reply the request latest in 30 days according to the feature of the request.

In accordance with the communiqué on the Basis and Procedures of Application to Data Responsible that was published by the Board of Personal Data Protection, and regarding your rights as personal data owners;

i. If your application will be replied in written form, no fee is requested until 10 pages. More than 10 pages, 1 Turkish lira fee can be requested for each page.

ii. When the reply is a digital platform such as in CD, flash drive, then the fee requested by our Company as the data responsible cannot be more than the cost of this digital platform recording.

Personal Data Owners have the following rights;

a. Knowing if their data are processed or not,

b. If processed, requesting information regarding this,

c. Knowing the purposes of personal data processing and whether they are used for the purposes or not.

d. Knowing the third persons that the personal data is transferred within the country or to abroad.

e. When the personal data are processed as incomplete or wrong, requesting their correction and in this context, requesting the notification of this operation to third persons whom the data were transferred.

f. Although the data were processed in conformity with KVK law and other provisions of the relevant laws, when the purposes for processing are no more present , then requesting their deletion and the notification of this operation to third parties whom the data were transferred

g. Objecting to a result that can occur against the person through the analysis of the data by automatic systems solely.

h. When the person has a loss because of the illegal processing of the data, then s/he has rights to request the compensation of this loss. However, persons have no right regarding the anonymised data in the Company. Our Company can share the personal data with relevant institutions and establishments for the purposes of the state authority or a legal duty to use its legal authorizations as required with the job-agreement relationship.

H. The duration that your personal data can be processed:

Your personal data that were processed with the purposes stated in hereby this “Disclosure Text regarding the Processing of the Personal Data“ by conforming to the KVK Law, will be deleted, destroyed or anonymised by us and will be continued to be used, when the purpose of processing stipulated in 7/f.1 Article of the KVK Law is removed and/or as stipulated by the legislation that the required time period is ended.

İ. Cases when our Company can process your personal data without your explicit consent as stipulated by the laws.

As stipulated by the 5th Article of the KVK Law, our Companies can process your personal data without your explicit consent that it has acquired in accordance with laws and as stated above in the below cases:

The cases that are overtly stipulated in the laws;

• If you are in a situation that because of actual impossibilities, as data owner you cannot express your explicit consent or when your explicit consent is not legally valid and it is compulsory to process your personal data for the protection of the life or whole body of you or another person.

• When the data processing of the personal data of the parties in the agreement is compulsory, with the condition to be directly related with the execution or conclusion of your Agreement with our Company or related companies/institutions, or the real persons and/or legal persons stated in Clause(C).

• When it is compulsory for our Company to fulfill its legal liability.

• When the personal data owner’s data is made publicly known by himself/herself

• When the data processing is compulsory for establishing a right or its protection

• When data processing is compulsory for the legitimate benefits of our Company, with the condition of not damaging the basic rights and liberties you have.

J. To make requests as stipulated by the Law on the Protection of the Personal Data:

You can submit your request to our Company about using your rights as stipulated by the 13th Article 1st paragraph of the KVK Law with the regulations in the relevant legislations and KVK Law and with the method(s) that will be determined by the Board, you can also submit your request by filling out and signing the application form in the Download Application Form web-address and with one of the methods below.

You can submit us a signed copy of the form including your explanations regarding your rights you requested to this address by hand, with official documents that detects your identity (for example ID card, driver’s license, passport, etc.);

* Sorgun Mahallesi, Acısu Mevkii, 07600 Manavgat/Antalya- Türkiye

You can send the form you’ll fill out and your official documents detecting your ID through Notary or

* You can send these in electronic form to this address as electronically signed or as mobile signed ; www.arcanushotels.com

* You can send your ID information (official documents detecting your ID) and the form you have filled out by using your e-mail address that is registered to our System that you have notified us before as data responsible. Our Company will reply latest in 30 days according to the feature of the request. The rights belonging to the personal data can just be used about these personal data. The requests of people other than this person with form and ID information will not be considered. The forms without official documents detecting the ID will not be considered. We’d like to remind you that even when the requests of deleting are completed, when requested by the official authorities, we are liable to share this information with them.