PRIVACY NOTICE ON PERSONAL DATA
This Privacy Notice Regarding Personal Data has been prepared under the Law on the Protection of Personal Data according to related countries (“DP Law”) to inform you about the collection, processing, transfer of your personal data and your rights under the DP Law.
As company ODEON DMCC (“Company” or “Odeonbeds”) residing at Jumeirah Lakes Towers, The Palladium Cluster C , Unit No: 907 , Dubai, UAE , we process your personal data as data controller, in accordance with the DP Law and relevant legislation, within the scope explained below.
For more detailed information, you can refer to the related countries Personal Data Processing and Protection Policy.
1. Personal Data We Process
As Odeonbeds, we may process some of your personal data, including the following:
• Your identity information including your name, surname, ID number, passport number, marital status, other information contained in your identity document or photocopy of your driver's license;
• Your location information, including residence and address information, and location information;
• Your contact information, including e-mail, phone number, mobile phone number;
• Bank account number, IBAN number, your financial information;
• Your family members information, including the name and surname of your spouse and children;
• Your event detection information included in the minutes of events occurring within the company;
• Your customer transaction information such as invoice, promissory note, check information, membership, customer request and complaint information, product/service information used/received;
• Your marketing information, including your past product/service purchase information and survey results;
• Your transaction security information, including IP address and access log information;
• Your health information, including blood group information, the information specified in the health report, allergen substance information, disability status information;
• Your audio-visual recordings, including CCTV;
2. Purposes of Processing Personal Data
We will process your personal data limited to the following purposes:
• Presenting our products and/or services and executing our sales processes,
• Execution of our product and/or service purchasing processes,
• Execution of our customer relations processes,
• Managing our customer return and exchange request processes,
• Examining and evaluating customer requests and complaints and communicating, if necessary,
• Carrying out activities for customer satisfaction,
• Updating, customizing and developing our products and services in line with your needs and demands,
• Sending e-mails, messages, newsletters and other publications about our new products or services, changes in our existing products or services, and our campaigns and promotions,
• Planning and execution of our communication processes,
• Managing cookies in order to improve the experience of our visitors on our websites, to identify requests and problems and to quickly conclude their searches. (For more detailed information, you can refer to our Cookie Policy),
• Execution of our marketing activities and advertising/campaign/promotion processes,
• Execution and supervision of our business activities and ensuring business continuity,
• Execution of our activities and performance of our obligations in accordance with the agreements made with suppliers, business partners and other third parties,
• Execution of our performance management processes for suppliers,
• Carrying out our service, maintenance, repair, inspection works,
• Execution of our finance and accounting works,
• Issuance of commercial credit cards by the company,
• Providing information to authorized public institutions and organizations, when necessary,
• Ensuring the realization of independent audits and managing the process,
• Follow-up of legal affairs directed against our company,
• Ensuring the physical space security of our buildings and facilities and creating and monitoring our visitor records,
• Compliance with legal regulations and fulfillment of our legal obligations,
• Evaluating job applications of employee candidates, conducting interviews and meetings, communicating with the people they refer to in their resumes.
3. Methods of Collecting Personal Data
As Odeonbeds, we collect your personal data through the following channels:
• E-mail, SMS, business cards,
• Telephone, Fax,
• CCTV (Closed Circuit Camera Records),
• Cookies and similar tracking technologies,
• Physical form,
• Our website,
• Postal, cargo, courier,
• Face-to-face meetings,
• Other physical and electronic media.
4. Legal Grounds for Data Processing
We process your personal data in accordance with the processing conditions specified in the relevant Articles of the DP Law of that country.
5. Transfer of Your Personal Data
We may transfer your personal data to our employees, business partners, shareholders, suppliers, group companies, company representatives, proxies and legally authorized public/private institutions and organizations, limited to the purposes stated above, in accordance with the processing conditions specified in the relevant Articles of the DP Law of that country.
6. Your Rights Regarding Personal Data
As a Data Subject, you have the following rights regarding your personal data in accordance with refer Articles of the DP Law of the relevant country :
• information about whether your Personal Data has been processed,
• if your Personal Data has been processed, information about such data processing,
• information about purposes for the processing of your Personal Data and whether your processed Personal Data has been used for such purpose,
• information about third parties in the relevant countries or abroad to whom your Personal Data is transferred,
• if your Personal Data has been incompletely or inaccurately processed, correction of such data processing, and requesting notification of the transaction made within this scope to the third parties to whom your personal data has been transferred,
• if the grounds for processing your Personal Data are no longer valid even if it has been processed in accordance with the provisions of the DP Law of relevant countries and other relevant laws, requesting of deletion or destruction of the Personal Data, and requesting the notification of the transaction made within this scope to the third parties to whom your personal data has been transferred,
• objection to any negative consequence of your processed Personal Data being analysed exclusively through automated systems,
• if you suffer any damages due to the illegal processing of your Personal Data, indemnification of such damages and losses.
You can submit your requests regarding these rights through the Data Subject Application Form on our website. Your applications will be answered in writing or electronically as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request.
Your application will be carried out free of charge. However, if the requested transaction requires an additional cost, the fees in the tariff determined by the Personal Data Protection Board will be requested from the applicant.
COOKIE POLICY
1. PURPOSE OF THE POLICY
As ODEONBEDS DMCC (“Odeonbeds” or “we”), we place certain cookies into the devices to ensure the proper functioning of our website (www.odeonbeds.com) and to provide the most relevant services to our visitors and members (“user(s)” or “you”). This Cookie Policy has been prepared to inform you about cookies and how to control cookies.
2. WHAT ARE COOKIES?
Cookies are small text files that are saved on your computer or mobile device when you visit our website. Along with these text files, other trackers such as web beacons, pixels or tags will also be considered cookies under this Cookie Policy.
3. INTENDED USE OF COOKIES
We use cookies for the following purposes:
• The safe operation of the site,
• Allowing Users to move on the site and benefit from the services and features provided,
• Storing information about users (on user devices or browser caches) and website usage,
• Making the site functional through the preferences of the users on the site and personalizing the site in accordance with the users,
• Analyzing the users' use of the site and determining the general tendency on the site,
• Increasing the performance of the website, making the use of the websites easier and/or faster,
• Offering new features through websites.
• Protection of user session variables.
4. GENERAL FEATURES OF COOKIES
Cookies function as session cookies and persistent cookies on our site and mobile application. Session cookies stop working when you close your browser. Persistent cookies can remain on your hard disk for a long time.
5. TYPES OF COOKIES USED
The types of cookies used on our site and mobile application are listed below. If the data we collect through these cookies is of the nature of personal data, the Odeonbeds Privacy Notice, which complements this Cookie Policy, will be applied. You can review the Privacy Notice for more information regarding this matter.
i. Necessary Cookies
These types of cookies are strictly necessary for our website to work securely, for users to move on our website and to benefit from the services and features provided. These types of cookies are essential for our website to work and cannot be disabled by users.
| Cookie Function | Explanation |
| Session | Session cookies are used to ensure the continuity of the session. |
| User ID | User ID cookies are used for users to see only their own information. |
| Security | Security cookies are used for security checks. |
| Load Balancing | Load balancing cookies are used to reduce the server load by distributing the load. |
ii. Preference and Functionality Cookies
Preference cookies collect information about users' preferences and allow us to remember language or other locale settings of users and customize our site to suit users. Such cookies may be set by us or by third-party providers whose services you have added to your pages. Some or all of these functions may not work properly if users disable such cookies
| Cookie Function | Explanation |
| Language | It saves the language selected by the user and offers options accordingly. |
| Location | It enables the approximate address (country, city, county, zip code) of the user to be determined thanks to the IP address, and the user to automatically select her own country in this way, and to show the dealers and promotion days in that region. |
| Source site | The source site is saved so that the user's preferences can be better understood. |
| Last visit and departure | It is used to update users on what has changed since their last visit to our site and to better understand users' preferences. |
| Page History | Page history cookies are used to keep track of which sites users visit in which order. If the user encounters an error when visiting the site, the cookie information is recorded in the log file for error reporting and resolution. |
iii. Analytics Cookies
We use analytical cookies to understand how users use our site. These cookies collect information in aggregate, give us an idea of how our site is used and help us improve our site. For example, these types of cookies show which pages are visited the most on the site and help to record the difficulties experienced within the site.
| Cookie Function | Explanation |
| Yandex Metrica Analytics | Such cookies enable the collection of all statistical data, thereby improving the presentation and use of the site. |
| Google analytics | Such cookies enable the collection of all statistical data, thereby improving the presentation and use of the site. By adding social statistics and interest data to these statistics, Google helps us better understand users. |
| Google Tag Manager | Web beacons work similarly to cookies and are placed on websites or in an email to track the behavior of a user visiting a website or sending an email. |
6. HOW TO CONTROL/DISABLE COOKIES?
You can change your cookie preferences by changing your browser settings. Depending on the possibilities offered by your browser, you can prevent the use of cookies, receive a warning before cookies are used, or disable or delete only some cookies. Cookies-related preferences must be deleted separately for each device (browser settings) from which you access our site.
Information on how to enable, disable or remove cookies is available on the Help screen on the internet browser provider's site.
• Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=tr
• Mozilla: https://support.mozilla.org/tr/kb/%C3%87erezleri%20engellemek
• Internet Explorer: https://support.microsoft.com/tr-tr/help/17442/windows-internet-explorer-delete-manage-cookies
• Safari: https://support.apple.com/kb/PH5042?locale=en-GB
• Opera: http://www.opera.com/help/tutorials/
We would like to kindly remind you that if you disable some cookies, various functions of our site may not work.
If you want to clear all the cookies left from the websites you visit, you can download these two programs that enable the deletion of tracking cookies by using the links below:
• http://www.spybot.info/en/download/index.html
• http://www.webroot.com/consumer/products/spysweeper/
7. CONTACT US
Odeonbeds shall be able to change the provisions of the Cookie Policy at any time. We will share the necessary information about the changes we have made with you on our website (www.odeonbeds.com) or through the e-mail address you have given us.
You can contact us via personaldata@odeonbeds.com for all your questions, comments and suggestions.
PROCESSING PERSONAL DATA AND SECURITY POLICY
1. PURPOSE OF THE POLICY
As ODEONBEDS DMCC (“Odeonbeds”), we collect and process some of your personal data in accordance with the Law on Protection of Personal Data of relevant countries (“DP Law”) and relevant legislation in order to provide our services in the best way possible.
This Personal Data Processing and Security Policy (“Policy”) has been prepared to determine and show for what purposes your personal data is processed, to which third parties it is transferred, your rights regarding your personal data and Odeonbeds' obligations in terms of processing and protecting personal data.
2. SCOPE OF THE POLICY
This Policy covers our activities regarding the processing of the personal data we have obtained from the following persons:
• Representative, attorney and shareholders of our company and group companies,
• Employees and officials of our business partners,
• Employees and officials of our suppliers,
• Our customers and potential customers,
• Our employee candidates, trainees, trainee candidates and the people they refer to in their applications,
• Family members of our employees,
• Legally authorized persons,
• Our visitors,
• Other third parties.
3. AUTHORITIES AND RESPONSIBILITIES
Odeonbeds Employees: Within the scope of all our business activities, they are obliged to comply with this Policy and relevant legislation.
Our suppliers: They are obliged to comply with this Policy and relevant legislation in all services they provide to Odeonbeds.
Odeonbeds Senior Management: They are responsible for ensuring that all our business activities are carried out in accordance with this Policy.
4. DEFINITIONS AND ABBREVIATIONS
The abbreviations in this Policy shall be used for the following definitions:
| ABBREVIATIONS | DEFINITIONS |
| Odeonbeds | ODEONBEDS DMCC |
| Personal Data | All the information relating to an identified or identifiable natural person. |
| Sensitive Personal Data | Personal data relating to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, clothing, membership to associations, foundations or trade-unions, health, sexual life, convictions and security measures, and the biometric and genetic data. |
| Data Subject | Natural persons whose personal data are processed. |
| Processing Personal Data | Any operation performed upon personal data such as collection, recording, storage, retention, alteration, re-organization, disclosure, transferring, taking over, making retrievable, classification or preventing the use thereof, fully or partially through automatic means or provided that the process is a part of any data registry system, through non-automatic means. |
| Explicit Consent | Freely given, specific and informed consent on a particular subject. |
| Anonymizing | Rendering personal data impossible to link with an identified or identifiable natural person, even though matching them with other data. |
| DP Law | Referred to the Personal Data Protection Law of all relevant countries. |
| Board | The Personal Data Protection Board of relevant countries. |
| Authority | The Personal Data Protection Authority of relevant countries. |
| Policy | Personal Data Processing and Security Policy of companies in relevant countries. |
| Data Controller | The natural or legal person determines the purpose and means of processing personal data and manages the place where the data is kept systematically. |
| Data Processor | The natural or legal person who processes personal data on behalf of the controller upon his authorization |
5. PERSONAL DATA PROCESSED BY ODEONBEDS
As a data controller, Odeonbeds processes the following personal data, including but not limited to those listed here, within the scope of its current activities:
| PERSONAL DATA GROUP | PERSONAL DATA |
| ID Information | Information such as name, surname, ID number, photo, date and place of birth, marital status, driver's license information, passport number, identity card serial number. |
| Contact Information | Email, phone number, mobile phone, social media account information associated with the contact. |
| Location Information | Information such as residence address, workplace address. |
| Personnel Information | Payroll information, disciplinary investigation, entry-exit document records, property declaration information, CV information, performance evaluation reports, Social Security Institution entry declarations, company title, tax registration and identification number, room registration number, reference information. |
| Legal Transaction Information | Information in correspondence with judicial authorities, information in the case file (execution information). |
| Physical Space Security Information | Entry-exit information of our customers and visitors to the campuses, records of CCTV in the campuses. |
| Transaction Security Information | IP address information and access logs. |
| Financial Information | Balance sheet information, financial performance information, credit and risk information, assets information, salary slips, Bank account information, payment amount, credit and debit card information, amount to be refunded, debt information. |
| Professional Experience Information | Diploma information, courses attended vocational training information, certificates, transcript information. |
| Marketing Information | Shopping history, survey results, information obtained as a result of campaign work. |
| Audio and Visual Recordings | Audio recording, camera footage taken. |
| Philosophical Belief, Religion, Sect and Other Beliefs | Information on religious affiliation and philosophical belief. |
| Association Membership | Association membership information in the resumes of employee or trainee candidates. |
| Foundation Membership | Foundation membership information in the resumes of employee or trainee candidates. |
| Health Information | Blood group information, personal health information, information specified in the health report, disability status information. |
| Criminal Conviction and Security Measures | Criminal record, criminal conviction or security measure information in the criminal record. |
| Family Members Information | Information about family members such as the person's number of children, spouse status. |
| Customer Transaction Information | Invoice, promissory note, check information, membership information, customer request and complaint information, product information received and used. |
| Complaint and Request Information | Complaint and request information regarding products and services. |
6. METHODS OF COLLECTING PERSONAL DATA
As Odeonbeds, we collect your personal data through the following channels:
• E-mail, SMS, business cards,
• Telephone, Fax,
• CCTV (Closed Circuit Camera Records),
• Cookies and similar tracking technologies,
• Physical form,
• Our website,
• Postal, cargo, courier,
• Face-to-face meetings,
• Other physical and electronic media.
7. PURPOSES OF PROCESSING PERSONAL DATA
As Odeonbeds, we give great importance to the privacy of your personal data we process, collect, and process your personal data in accordance with the general principles and processing conditions specified of the relevant countries DP Law. In this context, we process your personal data limited to the following purposes:
• Presenting our products and/or services and executing our sales processes,
• Execution of our product and/or service purchasing processes,
• Execution of our customer relations processes,
• Managing our customer return and exchange request processes,
• Examining and evaluating customer requests and complaints and communicating, if necessary,
• Carrying out activities for customer satisfaction,
• Updating, customizing and developing our products and services in line with your needs and demands,
• Sending e-mails, messages, newsletters and other publications about our new products or services, changes in our existing products or services, and our campaigns and promotions,
• Planning and execution of our communication processes,
• Managing cookies in order to improve the experience of our visitors on our websites, to identify requests and problems and to quickly conclude their searches. (For more detailed information, you can refer to our Cookie Policy),
• Execution of our marketing activities and advertising/campaign/promotion processes,
• Execution and supervision of our business activities and ensuring business continuity,
• Execution of our activities and performance of our obligations in accordance with the agreements made with suppliers, business partners and other third parties,
• Execution of our performance management processes for suppliers,
• Carrying out our service, maintenance, repair, inspection works,
• Execution of our repair and maintenance processes,
• Execution of our finance and accounting works,
• Providing information to authorized public institutions and organizations, when necessary,
• Ensuring the realization of independent audits and managing the process,
• Follow-up of legal affairs directed against our company,
• Ensuring the physical space security of our buildings and facilities and creating and monitoring our visitor records,
• Compliance with legal regulations and fulfillment of our legal obligations,
• Evaluating job applications of employee candidates, conducting interviews and meetings, communicating with the people they refer to in their resumes.
8. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
We process your personal data based on the following legal grounds:
• Pursuant to relevant country and related Articles of the DP Law, cases where we have obtained your express consent to process your personal data.
• Pursuant to relevant country and related Articles of the DP Law, clearly stipulated in the laws.
• Pursuant to relevant country and related Articles of the DP Law, if your personal data is required for the establishment or performance of a contract. For example, Odeonbeds' processing of customers' personal data in order to serve customers.
• Pursuant to relevant country and related Articles of the DP Law, fulfillment of the company's legal obligations. For example, Odeonbeds logs the access records of the people to whom it provides internet access in accordance with Turkish DP Law No. 5651 and forwards it to the relevant administration upon request.
• Pursuant to relevant country and related Articles of the DP Law, being made public by the data subject. For example, Odeonbeds' processing of customer or potential customers' contact addresses that they have made public on their websites in order to carry out purchasing, sales or marketing activities.
• Pursuant to relevant country and related Articles of the DP Law, Odeonbeds' establishment, exercise and protection of its own right. For example, in order for Odeonbeds to defend itself in a possible dispute or lawsuit, keeping personal data from the termination of the contractual relationship for the duration of the statute of limitations.
• Pursuant to relevant country and related Articles of the DP Law, if necessary for the legitimate interest of the company. For example, Odeonbeds' processing of potential customers' personal data to respond to potential customers' questions about products.
• Pursuant to relevant country and related Articles of the DP Law, stipulated in the law for sensitive personal data. For example, the processing of relevant personal data in terms of notifiable diseases.
• Pursuant to relevant country and related Articles of the DP Law, processing of personal data other than health and sexual life by persons or authorized institutions and organizations that are under the obligation to keep secrets in cases stipulated by law. For example, the collection and storage of health reports by the Joint Health And Safety Unit.
9. TRANSFER OF PERSONAL DATA
Within the framework of the data transfer conditions specified in relevant country and related Articles of the DP Law, in line with the purpose or purposes specified in other connected articles, your personal data may be transferred to our employees, business partners, group companies, suppliers, company representatives, authorities and legally authorized public/private institutions and organizations,
For example, as Odeonbeds,
• Due to the corporate identity of our company, we may share the requests and complaints from our customers with our group companies so that the necessary actions can be taken most efficiently
• We may share the data we collect from our customers with our suppliers in order to provide our services.
• We may share the necessary information with authorized public institutions and organizations if the events occurring on our company campuses are of judicial nature.
Odeonbeds may share your personal data with third parties abroad if one of the following conditions is met:
• If you give your explicit consent to the transfer activity abroad,
• If there is adequate protection in the country to which we will transfer the personal data, or
• If the party to whom the personal data will be transferred undertakes in writing to provide adequate protection and the Board approves this commitment, in the event that there is no adequate protection in the country,
10. STORAGE AND DESTRUCTION OF PERSONAL DATA
Your personal data processed for the purposes set out in this Policy will be stored and destroyed in accordance with the DP Law and the Regulation on the Deletion, Destruction or Anonymization of Personal Data. Odeonbeds stores and destroys your personal data in accordance with the Odeonbeds Personal Data Storage and Destruction Policy. You can request our Personal Data Storage and Destruction Policy at personaldata@odeonbeds.com in order to learn about the precautions we have taken regarding the safe storage and destruction of your personal data and the storage and destruction periods we have determined.
11. ENSURING THE SECURITY OF YOUR PERSONAL DATA
As Odeonbeds, we ensure the security of the personal data we process while providing our services in accordance with the DP Law and relevant legislation. In this context, Odeonbeds takes appropriate security measures and incorporates necessary security technologies in order to ensure the compliance of the personal data it processes with the law, to prevent illegal access and to ensure its preservation. Odeonbeds has prepared and implements a Personal Data Security Policy for the technical and administrative measures it has taken to ensure the security of personal data.
In addition, we take some additional technical and administrative measures in order to ensure the security of the sensitive personal data that we process as a data controller. In order to determine these measures, Odeonbeds has prepared and implements the Processing and Security of Sensitive Personal Data Policy.
Odeonbeds ensures the security of the personal data processed by acting in accordance with the two policies mentioned in this section and generally accepted good practices.
12. YOUR RIGHTS REGARDING YOUR PERSONAL DATA AND APPLICATION
As a Data Subject, you have the following rights regarding your personal data in accordance with relevant country and related Articles of the DP Law:
• information about whether your Personal Data has been processed,
• if your Personal Data has been processed, information about such data processing,
• information about purposes for the processing of your Personal Data and whether your processed Personal Data has been used for such purpose,
• information about third parties in Turkey or abroad to whom your Personal Data is transferred,
• if your Personal Data has been incompletely or inaccurately processed, correction of such data processing, and requesting notification of the transaction made within this scope to the third parties to whom your personal data has been transferred,
• if the grounds for processing your Personal Data are no longer valid even if it has been processed in accordance with the provisions of the relevant countries of DP Law and inlinewith other connected laws, requesting of deletion or destruction of the Personal Data, and requesting the notification of the transaction made within this scope to the third parties to whom your personal data has been transferred,
• objection to any negative consequence of your processed Personal Data being analyzed exclusively through automated systems,
• if you suffer any damages due to the illegal processing of your Personal Data, indemnification of such damages and losses.
You can submit your requests regarding these rights through the Data Subject Application Form on our website.
Your application will be carried out free of charge. However, if the requested transaction requires an additional cost, the fees in the tariff determined by the Personal Data Protection Board will be requested from the applicant.
Your applications will be answered in writing or electronically as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request. If your request is rejected, your application will be answered with justification.
13. REFERENCES AND BASIS
• Law on the Protection of Personal Data of relevant countries.
14. RELATED DOCUMENT
• General Privacy Notice on Personal Data of relevant countries.
• Cookie Policy
• Personal Data Storage and Destruction Policy
• Personal Data Security Policy of companies in relevant countries.
• Policy on Processing and Security of Sensitive Personal Data