Website Privacy Agreement
How the information we obtain about you and the services you request, while you visit this website and use the services we offer through it, will be used and protected is subject to the terms set out in this “Privacy Policy”. By visiting this website and requesting to use the services we offer through it, you accept the terms set out in this “Privacy Policy”.
Owing to the sensitive nature of the work we have carried out to date as lecielh.com, the data received from our customers and prospective customers have been kept confidential and have never been shared with third parties. The protection of personal data is a fundamental policy of our company. Even before any legal regulation existed, our company and its affiliates attached great importance to the confidentiality of personal data, adopted it as a working principle and instructed their employees to work in accordance with this principle. As lecielh.com, we also undertake to comply with all the responsibilities introduced by the Law on the Protection of Personal Data. Our company’s principles on the protection of personal data also cover our affiliates.
This Policy, prepared by our Company, has been drawn up in accordance with Law No. 6698 on the Protection of Personal Data (“KVKK”). As of today, the Law has entered into force with all of its provisions. Data obtained from you with your consent, or on the basis of the other legal grounds listed in the Law, will be used to raise the quality of the services we provide and to improve the services offered to you and our quality policy. In addition, some of the data we hold are stripped of their personal character and anonymised. These data are used for statistical purposes and are not subject to the application of the Law or to our Policy. The lecielh.com Policy on the Protection and Processing of Personal Data aims to protect the data, obtained automatically, of our customers, our prospective customers, our employees, the customers and employees of the companies working with us as solution partners, and other persons, and contains the rules relating to them.
Our Company has the right to amend our policy and our internal regulations, provided that this complies with the Law and ensures better protection of personal data.
a) Compliance with the law and the rules of good faith: lecielh.com questions the source of the data it collects or receives from other companies and attaches importance to their having been obtained lawfully and in accordance with the rules of good faith. Within this framework, lecielh.com gives the necessary warnings and notifications for the protection of personal data to third parties selling the services it offers (including agencies and other intermediaries).
b) Being accurate and, where necessary, kept up to date: lecielh.com attaches importance to all data held within the organisation being accurate and free of incorrect information and, finally, to updating personal data when any change in them is communicated to it.
c) Processing for specified, explicit and legitimate purposes: lecielh.com processes data only to the extent limited to the purposes of the services it offers and for which it has obtained the consent of the persons concerned during the service. It does not process, use or allow others to use data outside its business purpose.
d) Being relevant, limited and proportionate to the purposes for which they are processed: lecielh.com uses data only within the limits of the purposes for which they are processed and to the extent required by the service.
e) Being retained for the period laid down in the relevant legislation or necessary for the purpose for which they are processed: lecielh.com retains data arising from contracts for as long as the statutory limitation periods for disputes and the requirements of commercial and tax law require. When these purposes cease to exist, however, it deletes or anonymises the data.
We would stress that these principles listed above apply regardless of whether lecielh.com has collected or processed the data on the basis of consent or otherwise in accordance with the law.
Under Article 11 of the Law on the Protection of Personal Data, you have the rights listed below. To make it easier for you to exercise these rights, lecielh.com has also prepared an application form for you.
Persons whose personal data are processed, by applying to our contact person announced by lecielh.com on our website, have the following rights regarding their own data:
a) to learn whether your personal data are being processed,
b) to request information about it if their personal data have been processed,
c) to learn the purpose of the processing of personal data and whether they are used in accordance with that purpose,
d) to know the third parties in Turkey or abroad to whom personal data are transferred,
e) to request the rectification of personal data if they have been processed incompletely or inaccurately,
f) to request the erasure or destruction of personal data under the conditions laid down in the Law,
g) to request that the operations carried out under subparagraphs (d) and (e) be notified to the third parties to whom the personal data have been transferred,
h) to object to a result to the detriment of the person concerned arising from the analysis of the processed data exclusively by means of automated systems,
i) to request compensation for damage if they suffer damage as a result of the unlawful processing of personal data.
As lecielh.com, we respect these rights.
Principle of Maximum Economy / Principle of Parsimony
Under this principle of ours, called the principle of maximum economy or the principle of parsimony, the data reaching lecielh.com are entered into the system only to the extent necessary. For this reason, which data we collect is determined according to the purpose. Data that are not necessary are not collected. Other data reaching our Company are likewise transferred to the company’s information systems. Surplus information is not recorded in the system; it is deleted or anonymised. These data may be used for statistical purposes. Among the special categories of data, health data are collected only to provide better service to customers and to protect their health; limited to the same purpose and depending on the type of service the customer prefers, they are transferred to supplier companies providing hotel, airline and transfer services resident in Turkey or abroad and to the relevant foreign agency, and are kept with care in the system.
Erasure of personal data
When the periods for which data must be retained by law expire, judicial proceedings are concluded or other requirements cease to exist, our company erases, destroys or anonymises the personal data, either of its own motion or at the request of the data subject.
Accuracy and up-to-dateness of data
As a rule, the data held by lecielh.com are processed on the basis of the statements of the data subjects and in the form in which they were declared. lecielh.com is not obliged to investigate the accuracy of the data declared by customers or by persons who contact lecielh.com, and for legal reasons and owing to our working principles it does not do so. Declared data are deemed accurate. The principle that personal data be accurate and up to date has also been adopted by lecielh.com. Our Company updates the personal data it has processed on the basis of official documents it receives or at the request of the data subject, and takes the necessary measures for this purpose.
Confidentiality and data security
Personal data are confidential, and lecielh.com observes this confidentiality. Within the company, personal data may be accessed only by authorised persons. All necessary technical and administrative measures are taken to protect the personal data collected by lecielh.com, to prevent them from falling into the hands of unauthorised persons and to ensure that our customers and prospective customers suffer no harm. Within this framework, it is ensured that the software complies with standards, that third parties are selected with care and that the data protection policy is observed within the company.
Owing to Covid-19 and epidemic diseases, additional health data may be requested from or collected about our employees, and the data collected may be shared with the relevant official authorities.
The collection and processing of personal data by lecielh.com will be carried out in line with the purposes stated in the clarification text. Data are collected and processed for the purpose of concluding the contract and providing better service to customers.
Collection and processing of data for a contractual relationship
Where a contractual relationship has been established with our customers and prospective customers, the personal data collected may be used without obtaining the customer’s consent. However, such use takes place in line with the purpose of the contract. Data are used to the extent required for the better performance of the contract and by the needs of the service and, where necessary, are updated by contacting the customers. By contrast, the data that our prospective customers have themselves left with us are processed in order to offer them easier and higher-quality service afterwards. If these data have not turned into a contractual relationship, they are deleted upon request.
Data of Business and Solution Partners
lecielh.com makes it a principle to act lawfully when sharing data with both its business partners and its solution partners. Data are shared with business and solution partners only under a data confidentiality undertaking and only to the extent required by the service, and these parties are required without exception to take measures to ensure data security.
Processing of data for advertising purposes
In accordance with the Law on the Regulation of Electronic Commerce and the Regulation on Commercial Communications and Commercial Electronic Messages, electronic messages for advertising purposes may be sent only to persons whose prior consent has been obtained. The consent of the person to whom the advertisement will be sent must exist in explicit form. lecielh.com likewise observes the details of “consent” laid down under the same legislation. In order for electronic messages to be sent, personal data are transferred to service providers and, as required by the Regulation on Commercial Electronic Messages, to İleti Yönetim Sistemi A.Ş.
Data processing carried out due to a legal obligation of the Company or because it is expressly provided for by law
Personal data may be processed without separate consent where the processing is expressly provided for in the relevant legislation or for the purpose of fulfilling a legal obligation laid down by legislation. The type and scope of the processing must be necessary for the legally permitted data processing activity and must comply with the relevant legal provisions.
Data processing by the Company
Personal data may be processed in line with the services offered by the Company and its legitimate purposes. However, the data may under no circumstances be used for unlawful services.
Processing of special categories of personal data
Under the Law, data relating to persons’ race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and dress, membership of associations, foundations or trade unions, health, sex life, criminal convictions and security measures, as well as biometric and genetic data, are special categories of personal data. When processing special categories of personal data, lecielh.com also takes the adequate measures determined by the Board.
In order to provide its services better, lecielh.com may process special categories of data, with the consent of the persons concerned, only for the purpose for which they were collected. Under the circulars and legal regulations issued in connection with Covid-19, the facility at which you make a reservation through us may request certain personal data from guests, including special categories of personal data such as health data relating to themselves and their relatives. Where necessary, these personal data may be shared with official authorities and health institutions.
Data obtained through membership procedures
If you become a member of lecielh.com, the personal data you share with us for the membership procedure are processed in our systems. If you become a member of our system through Facebook, Google or other social media tools, the information about you that the relevant social media tool provides to its partners, such as your first name, last name, profile picture and e-mail address, is accessed and transferred to lecielh.com’s systems.
Data processed by automated systems
lecielh.com acts in accordance with the Law with regard to data processed by means of automated systems. Information obtained from these data may not be used against a person without that person’s explicit consent. However, lecielh.com may, using the data in its own system, make decisions concerning the persons with whom it will do business.
Domestic and International Transfer of Personal Data
In order for your reservation to be completed and the service to be provided to you, your personal data are shared with supplier companies providing hotel, airline and transfer services resident abroad and with the relevant foreign agency. So that your trip can take place, your personal data may also be shared with other electronic platforms located in Turkey and abroad, in order to enable you to search for, book and stay at hotels with which lecielh.com has no agreement.
Your Rights Regarding Your Personal Data
As a data subject, by applying to lecielh.com, you have the right:
to learn whether your personal data are being processed,
to request information about it if your personal data have been processed,
to learn the purpose of the processing of your personal data and whether they are used in accordance with that purpose,
to know the third parties in Turkey or abroad to whom your personal data are transferred,
to request the rectification of your personal data if they have been processed incompletely or inaccurately, and to request that the operations carried out in this context be notified to the third parties to whom your personal data have been transferred,
to request the erasure or destruction of your personal data where the reasons requiring their processing have ceased to exist, even though they have been processed in accordance with Law No. 6698 and the provisions of other relevant laws, and to request that the operations carried out in this context be notified to the third parties to whom your personal data have been transferred,
to object to a result to your detriment arising from the analysis of your processed data exclusively by means of automated systems,
to request compensation for damage if you suffer damage as a result of the unlawful processing of your personal data.
If you submit your requests concerning the rights listed above to our Company in accordance with the application procedures laid down in the Communiqué on the Procedures and Principles of Applications to the Data Controller, lecielh.com will conclude your request as soon as possible according to its nature and within 30 (thirty) days at the latest. However, if the operation entails an additional cost, lecielh.com may charge the fee set out in the tariff determined by the Personal Data Protection Board.
Functional and Analytical
These cookies contain data for remembering your preferences, for the effective use of the website, for optimising the site to respond to users’ requests and about how visitors use the site. By their nature, cookies of this type may contain personal information such as your user name.
Third-Party Cookies
The lecielh.com websites/mobile applications/mobile websites work with reliable, well-known third-party advertising providers. Third-party service providers place their own cookies in order to show you personalised advertisements. Cookies placed by third parties collect and process visitors’ browsing information on websites and analyse how they use them.
Commercial cookies
These serve to enhance your user experience by presenting products/content similar to those you are targeting in line with your interests and choices, and by offering a more advanced, personalised portfolio of advertisements. The session, persistent, functional and analytical, and commercial cookies described above are retained in the background for approximately 2 (two) months, and the necessary adjustments can be made in the individual’s web browser settings. The procedure for removing them through these settings may vary depending on the web browser.
How can I delete cookies?
Many web browsers are set, from their first installation on your computer, to accept and use cookies automatically. Using the help or settings menus of your web browser, you can block cookies or have a warning shown when a cookie is sent to your device. To learn about the different ways of managing cookies and to obtain detailed information on how to adjust the settings of the browser you use, you can refer to your browser’s instructions or help screen.
Processing of data for the employment relationship
Our employees’ personal data may be processed without obtaining consent to the extent necessary for the employment relationship and health insurance. However, lecielh.com ensures the confidentiality and protection of its employees’ data.
Processing Pursuant to Legal Obligations
lecielh.com may process its employees’ personal data without separate consent where the processing is expressly provided for in the relevant legislation or for the purpose of fulfilling a legal obligation laid down by legislation. This is limited to obligations arising from the law.
Processing for the Benefit of Employees
lecielh.com may process personal data without obtaining consent for operations that are in the interest of the company’s employees, such as private health insurance. lecielh.com may also process employees’ data in connection with disputes arising from the employment relationship.
Processing of special categories of personal data
Under the Law, data relating to persons’ race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and dress, membership of associations, foundations or trade unions, health, sex life, criminal convictions and security measures, as well as biometric and genetic data, are special categories of personal data. When processing special categories of personal data, lecielh.com, in addition to obtaining the consent of the data subject, also takes the adequate measures determined by the Board. Special categories of personal data may be processed without the person’s consent only in connection with, and limited to, the cases permitted by the Law. The special categories of data obtained from our employees so that they can benefit from insurance and health services are used solely for that purpose.
Data processed by automated systems
Data processed by automated systems in relation to employees may be used in internal promotions and performance evaluations. Our employees have the right to object to a result to their detriment, and they exercise this right by following internal company procedures. Employees’ objections are likewise assessed within the company.
Telecommunications and internet
The computers, telephones, e-mail and other applications allocated to employees within the company are allocated to the employee solely for business purposes. The employee may not use any of these means allocated to them by the company for private purposes or communications. The company may monitor and inspect all data on these tools. From the moment they start work, the employee undertakes not to keep any data or information other than business-related data on the computer, telephones or other tools allocated to them.
Personal data may be shared by lecielh.com with business and solution partners and with lecielh.com’s affiliates in order for the service to be performed.
lecielh.com may transfer personal data to the persons and organisations listed below for specific purposes:
» to lecielh.com’s business partners, limited to ensuring the fulfilment of the purposes for which the business partnership was established,
» to lecielh.com’s suppliers, limited to ensuring that the services which our Company procures from suppliers through outsourcing and which are necessary to carry out our Company’s commercial activities are provided to our Company,
» to lecielh.com’s solution partners, limited to ensuring the conduct of our Company’s commercial activities that require the participation of its affiliates,
» to lecielh.com’s affiliates.
lecielh.com is authorised to transfer personal data within Turkey and abroad within the conditions laid down in the Law and determined by the Board, in compliance with the other conditions of the Law and subject to the person’s consent.
lecielh.com acknowledges that, under the Law, the data subject has the right to give their consent before the data are processed and, after the data have been processed, the right to determine what becomes of their data.
By applying to our contact person announced by lecielh.com on our website, with regard to personal data, the data subject has the right:
a) to learn whether their personal data are being processed,
b) to request information about it if their personal data have been processed,
c) to learn the purpose of the processing of personal data and whether they are used in accordance with that purpose,
d) to know the third parties in Turkey or abroad to whom personal data are transferred,
e) to request the rectification of personal data if they have been processed incompletely or inaccurately,
f) to request the erasure or destruction of personal data under the conditions laid down in Article 7,
g) to request that the operations carried out under subparagraphs (d) and (e) be notified to the third parties to whom the personal data have been transferred,
h) to object to a result to the detriment of the person concerned arising from the analysis of the processed data exclusively by means of automated systems,
i) to request compensation for damage if they suffer damage as a result of the unlawful processing of personal data.
However, persons have no rights in respect of data anonymised within the Company. lecielh.com may share personal data with the relevant institutions and organisations as required by the business and contractual relationship, or so that a judicial authority or a state authority can exercise its statutory powers.
Personal data owners may submit their requests concerning the rights set out above to the Company by completing in full the application form available on the Company’s official website, www.lecielh.com, signing it with a wet signature and sending it by registered mail with return receipt, together with photocopies of their identity documents (for an identity card, a photocopy of the front side only), to 16 Eylül Mah. 3052.Sk No:67/A 35930 Çeşme/İzmir. Your applications will be answered as soon as possible according to their content, or within 30 days at the latest after they reach our company. You must submit your applications by registered mail with return receipt. Furthermore, only the part of your application that concerns you will be answered; an application made about your spouse, relative or friend will not be accepted. lecielh.com may request further relevant information and documents from applicants.
The data held by lecielh.com, whether of employees or of other persons, are confidential. No one may, without a contract or legal basis, use these data for any other purpose, copy them, reproduce them, transfer them to others or use them outside business purposes.
All necessary technical and administrative measures are taken to protect the personal data collected by lecielh.com, to prevent them from falling into the hands of unauthorised persons and to ensure that our customers and prospective customers suffer no harm. Within this framework, it is ensured that the software complies with standards, that third parties are selected with care and that the data protection policy is observed within the company. Security measures are continuously renewed and improved.
lecielh.com has the necessary internal and external audits carried out regarding the protection of personal data.
When lecielh.com is notified of any breach concerning personal data, it takes immediate action to remedy the breach. It minimises and compensates for the data subject’s damage. Where personal data have been obtained by unauthorised outside persons, it immediately notifies the Personal Data Protection Board.
Applications regarding the notification of breaches may also be made in accordance with the procedures set out at the addresses.
Contact
For your questions and requests regarding the privacy agreement, you may print out the form below, complete it and send it by registered mail with return receipt to the address given below.
lecielh.com
Last Updated: April 28, 2022