In particular, we inform you about how we use, disclose, protect, and, finally, how you can exercise your rights regarding the personal data we collect from you.
- Nature of Personal Data Collected through the Site
Massi processes the personal data provided by you and relating to you in the following cases:
When you browse the Site;
When you make a reservation directly through the Site at the following hotels and villas:
When you consent to receive our newsletters and other marketing/commercial information;
When you contact us to ask a question, make a complaint, or apply for a job via the contact form.
In this context, Massi collects and processes the following personal data:
Your identity and contact information: your gender, surname, name, email address, telephone number, the ages of each child related to a reservation made on the Site, and the identities of the persons related to a reservation made on the Site or through referred reservation sites, depending on the situation;
Your invoice information: your invoice address, cell phone number;
Your payment information;
Any other information that you directly and voluntarily provide to us when using the Site.
The mandatory or optional nature of any information that you need to provide will usually be indicated with a star (*) at the time of collection. Failure to provide this information may result in Massi being unable to process your request.
By providing personal data about yourself to Massi, you consent that such data will be current, accurate, complete, and understandable.
Legal Basis and Purposes of Processing Your Personal Data
Massi processes your personal data for the purposes of providing and improving the services offered on the Site, managing, measuring, analyzing, and improving them, carrying out marketing activities, providing customer service, complying with management and legal obligations, and protecting and defending our legal rights.
The processing of your personal data is based on the following legal grounds:
The existence of your explicit consent in cases where data processing is based on consent;
The necessity of processing data for the performance of a contract or for the conclusion of a contract in cases where data processing is necessary to enter into or perform a contract;
The fulfillment of legal obligations in cases where data processing is necessary to fulfill our legal obligations.
- Legal Basis and Purposes of Processing Your Personal Data
Massi’s primary goal in collecting personal data is to provide you with a secure, optimal, effective, and personalized experience.
Massi is committed to collecting and processing personal data in a lawful and fair manner.
The data processing applied by Massi aims to achieve specific, clear, and legitimate purposes.
Your data may be processed, in particular, for the following purposes:
To provide services to you, such as managing/recording your reservations/payments.
In this context, the legal basis for data processing is the performance of the contract between Massi and you.
To address any complaints you may have, respond to your inquiries and requests: Massi may use the data collected to respond to your requests related to the operation of the Site, Massi’s services, and your reservations.
In this case, if the relevant request is related to the contractual relationship between you and Massi, the legal basis for data processing will be the performance of the contract. Otherwise, the legal basis will be Massi’s legitimate interests, particularly Massi’s financial interests in responding to your inquiries and ensuring quality customer service.
In this context, the legal basis for data processing is Massi’s legitimate interests, particularly Massi’s financial interests in providing you with an optimal browsing experience, suitable content, and improving its Site and services.
To send you marketing/commercial content: If you consent, Massi may send you emails containing information about its activities and services.
In this case, the legal basis for data processing is Massi’s legitimate interests, particularly Massi’s financial interests in providing personalized services to you, understanding your needs, and adapting its services to earn your loyalty.
- Storage of Your Personal Data
Massi will retain your personal data for the period necessary to achieve the purposes for which they were collected and processed.
However, in cases where Massi has a legal obligation or needs to consider the statute of limitations for asserting, using, or defending its legal rights, Massi may keep your personal data for a longer period (in archives), as follows:
For data collected in the context of a reservation, for 5 years after the end of the commercial/contractual relationship;
For all data collected for direct marketing purposes, 3 years after the last communication with you;
For data required for accounting purposes, for 10 years;
For any request/claim (or during a litigation process, in accordance with the applicable statute of limitations), until the processing of your request is completed;
For applicant data, 2 years after the last communication with the applicant if the applicant has not consented to a longer period; beyond this period, the relevant data will be archived for 4 years.
4. Disclosure of your personal data
Your personal data may be disclosed by Massi to service providers in order for them to provide their services related to the Site (such as accommodation, maintenance, payment processing, risk and fraud protection, and Site optimization), perform data analysis, and execute marketing campaigns. These service providers may only have access to your data for the purposes of providing these services, and they remain bound by the same security and confidentiality obligations as Massi.
The personal data required to make a reservation at one of Massi’s hotels or villas will remain with Massi. In the case of bookings made through reservation sites, the relevant provisions are subject to the service provider that provides the reservation system.
When you stay at one of Massi’s hotels or villas, your personal data will be used by Massi to facilitate your stay in their establishments for their own specific and distinct purposes as data controllers. In summary:
Massi will process your personal data to collect the necessary personal data to organize your stay in one of its hotels or villas and to transmit this data to the relevant hotel and villa staff using Site reservation forms and reservation management systems managed by Massi.
Massi also manages a database that includes all customer information for its hotels and villas operating under the Massi brand.
Massi will process your personal data to manage the contract relationship with you (such as invoicing, payment and reservation management), perform marketing activities, and comply with legal obligations.
Data related to your stay, preferences, and satisfaction may be shared among hotels and villas operating under the Massi brand to improve service quality and enhance the experience at each hotel or villa. In this context, your data will be processed by the relevant hotels and villas as determined by Massi in order to protect your rights and freedoms while also achieving this legitimate interest in data usage in partnerships established by Massi.
As shown in Section 7 below, you may object to the sharing of this data between Massi and these hotels at any time by contacting us. You may also request a summary of the basic principles of this joint control agreement.
Your personal data may also be shared by Massi with its controlling corporate affiliates for the management and/or analysis of Massi’s loyalty programs [verify purposes]. In this context, Massi and its affiliates will act as separate data controllers for their own distinct purposes.
Finally, Massi may share your personal data with a third party in whole or in part if Massi is acquired or sold by a third party, as you have agreed to this provision.
5. Transfer of your personal data
The recipients to whom Massi may transfer your personal data, as listed above, may be located outside the Turkish Economic Area, for example.
In such a case, Massi will be obliged to ensure that such recipients take all necessary corporate and technical measures required under applicable data protection laws to ensure an adequate level of protection of your personal data (particularly in the form of the adequacy decision of the Turkish Data Protection Commission, the signature of the Standard Contractual Clauses prepared by the Commission, or a copy of these documents can be obtained upon request from Massi Turizm Ticaret Anonim Şirketi).
6. Your Rights
You have the following rights with regards to your personal data:
Right of access: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and certain information.
Right to rectification: You have the right to obtain the rectification of inaccurate personal data concerning you and to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure: In certain circumstances, you have the right to obtain the erasure of personal data concerning you.
Right to restriction of processing: In certain circumstances, you have the right to obtain restriction of processing of your personal data.
Right to data portability: You have the right to receive the personal data concerning you, which you have provided to Massi, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from Massi.
Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, which is based on the legitimate interests pursued by Massi. Massi may demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. You also have the right to object at any time to processing of your personal data for direct marketing purposes.
Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with the supervisory authority if you believe that the processing of your personal data carried out by Massi breaches the applicable data protection laws.
Right to give instructions regarding the use of your data after your death: You have the right to give instructions to Massi regarding the use of your personal data after your death.
To exercise any of these rights, please contact Massi Turizm Ticaret Anonim Şirketi via postal mail or email at [email protected].
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