SITORBİS/COEN M.I.C.E PLANNING SERVICES Protection of Personal Data and Privacy Policy

The protection and the use of the data which we provide according to our customers and visitors demand, as they log onto Sitorbis.com website and the mobile application, and as they benefit from our services which we provide in the aforementioned website and the mobile application, are hereby subject to the conditions presented in this ‘Privacy Policy’. When you visit this website and use this mobile application, you indicate a request to benefit from the services we provide and you accept the conditions presented in this ‘Privacy Policy’. Sitorbis.com is a website within the scope of a project by Coen M.I.C.E Planning Services and hereupon only ‘Sitorbis’, which is the name of the project, will be used in this agreement.  The word ‘firm’ will hereupon refer to ‘Sitorbis’. 

        I. The aim of the protection and the processing of personal data policy

As Sitorbis, our main objective while processing your data is to ensure the protection of your data as it is processed.   Since its inception, our firm has given utmost importance to privacy in processing personal data and accordingly has instructed its employees to pay strict attention to this subject. Furthermore, we hereby commit to assuming all the responsibilities which are brought by the Personal Data Protection Law no. 6698. We guarantee our firm’s utmost attention to the protection of personal data to continue in its dealings with its partners.

      II. The scope of and the changes in the protection and processing of personal data policy

This policy is created by our firm according to the Personal Data Protection Law no. 6698.  The data which is acquired through the consent of our customers or by other means which comply with the law will be used to improve the quality of the services which we provide and to refine our quality policy.  Furthermore, all the personal data provided to us by our customers and visitors will be stored by our firm until its anonymization at the end of the legal term according to the law no. 6698. Aforesaid data to be anonymized will be used to create statistics which will help shape the special interest tourism (SIT) on a sectoral and academical basis at a global level and following their anonymization at the end of the legal term, they are not to be subjected to the practice of law or our policy. Sitorbis Protection and Processing of Personal Data Policy aims to protect the data acquired by our visitors, our users which demand our services, our employees and the customers and by the employees and the customers of the firms with which we are in partnerships or by any third party private or legal person, and includes regulations concerning these data.

Our firm reserves the right to make changes to its policy and regulation, in accordance with law no. 6698 to better improve its protection of personal data.

  1. Principles to Be Followed in Protection of Personal Data   

Your personal data will be processed by our firm in accordance with the principles set forth by the Personal Data Protection Law no. 6698. These principles are indicated below and the scope in which our firm is to comply with them is stated explicitly.

  1. Lawfulness and conformity with rules of bona fides:  Sitorbis attaches great importance to handling the data it acquires with good faith and in compliance with the law.  Within this scope in order to protect personal data our firm shares the necessary information with and makes the necessary warnings to its partners.
  2. Accuracy and being up to date, where necessary: Sitorbis guarantees the accuracy of the data it has of its customers and visitors and not to collect any false data and, when it is informed, to make the necessary updates in case of any change in personal data.
  3. Being processed for specific, explicit and legitimate purposes:  Storbis.com processes data only at the moment of service it indicates and provides, and only for the purposes for which it has the user’s consent. It does not process, use or let others use the data outside of the scope of the service,
  4. Being relevant, limited to and proportionate to the purposes for which they are processed: Sitorbis does not use the data it acquires, out of the purpose for which they are processed. Our firm guarantees its processing of personal data only in relation to the service it offers.
  5. Being retained for the period of time stipulated by relevant legislation or the purpose for which they are processed: Sitorbis stores the data it acquires as a result of the contracts the terms of which the customers' consent to at its data bank, as so long as the periods of limitation ensured for dissensions and periods of time which are in the scope of the tax procedure law.  At the expiration of these periods, it deletes or anonymizes the aforementioned data.

        IV. The Rights of Our Customers And Visitors Within the Scope of the Law on the Protection of Personal Data

The legal rights of the persons whose personal data are used are guaranteed under article 11 of the law on the protection of personal data.   In accordance with this article, our firm informs its visitors and customers of the rights they hold and possess below.

Our customers and visitors whose personal data is processed have the right to apply to the data controller announced at our website and;

  1. to learn whether his personal data are processed or not,
  2. to request information if his personal data are processed,
  3. to learn the purpose of his data processing and whether this data is used for intended
    purposes, to know the third parties to whom his personal data is transferred at home or abroad,
  4. to request the rectification of the incomplete or inaccurate data, if any,
  5. to request the erasure or destruction of his personal data under the conditions laid down in Article 7, to request notification of the operations carried out in compliance with subparagraphs (d) and (e) to third parties to whom his personal data has been transferred, to object to the processing, exclusively by automatic means, of his personal data, which leads to an unfavorable consequence for the data subject, to request compensation for the damage arising from the unlawful processing of his personal data. 

   Maximum Savings Policy/Scrimping Policy on the Use of Personal Data

Pursuant to our policy called as maximum savings policy or scrimping policy, the data received by “Sitorbis.com” are processed into the system as required and which data to be collected will be determined in accordance with the purpose. Therefore, unnecessary data will not be collected. Other data submitted to our firm are transferred to the information system of the firm in the same way. Redundant information is not stored in the system, they are either deleted or anonymized.  These data may be used for statistical purposes.   Among the special quality data, the data relating to health are only kept in the system to provide better service to the customers and to protect their health.

Deletion of personal data

In the case of the expiration of the period of limitation necessitated by law, or judicial procedures are completed or other requirements no longer exist, these data shall be deleted or anonymized automatically by Sitorbis or upon the request of the relevant person.

Accuracy and currency of data

The data within the body of Sitorbis.com are processed as declared by the relevant persons as a rule. Sitorbis is not obliged to check up on the accuracy of the data declared by the customers or the persons who contact Sitorbis.com. Furthermore, this is also contrary to the Laws and our working principles.  The data declared by the customers and the users are regarded as correct and accurate. The principle of accuracy and currency of personal data has also been adopted by Sitorbis. Sitorbis.com updates the personal data processed upon the request of the relevant person when necessary and guides its users/customers to carry out the necessary updates.

Confidentiality and data security

Personal data are confidential.  Sitorbis adheres to this confidentiality and providing the necessary conditions ensures the protection of data. Only authorized persons within our firm have the right to access the personal data  Within this framework, it shall be ensured that the software complies with the standards, third parties are selected with caution and data protection policy is observed within the firm.

     V. Purposes of Data Processing

The collection and processing of personal data by Sitorbis shall be executed in line with the purposes stipulated in the text of clarification. The data are collected and processed to draw up contracts and provide better services to the customers.

Collection and processing of data for the contractual relationship

In the case of a contractual relationship with our customers and potential customers or users, the collected personal data may be used without the approval of the customers. Nevertheless, this use will be in line with the for the purpose of the contract The data shall be used for better execution of the contract and as required by the services and updated, if necessary, by contacting the customers.  Besides, the data provided to us by our potential customers will be processed to provide them easier and better quality services in the future. These data will be deleted upon requests in case of a lack of any contractual relationship.

Data of Business and Solution Partners

Sitorbis adopts as a principle to act in compliance with the law on the protection of personal data when exchanging data both with business and solution partners. The data processed anonymously and exchanged as a list with the business and solution partners in line with the understanding of data confidentiality are exchanged only within the scope of the service and it is definitely ensured that these parties take measures regarding the data security.

Data processing for advertisement purposes

Electronic messages for advertisement purposes can only be sent to the persons with prior consent in compliance with the Law on the Regulation of E-Commerce and the Law on Commercial Communication and Commercial Electronic Messages. Explicit consent of the person is required to send advertisements. The scope of the aforementioned consent is to be shared in detail with the customer under the heading ‘Keep me updated on special offers and changes” and Sitorbis will also obey the details of this consent. Personal data may be processed without prior consent when it’s stipulated explicitly in the relevant legislation or to fulfill a legal obligation on the part of Sitorbis, specified in the legislation. Nevertheless, the type and scope of the data processes should be required for data processing activity that is permitted by the Laws and they should comply with the relevant legal provisions.

Data processing of the company

Personal data may be processed pursuant to the legal purposes and the services of Sitorbis.  However, the data shall not be used for services contrary to the laws under any circumstances.

  Processing of special quality data

Pursuant to the Law, race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothes, membership of an association, foundation or union, health, sexual choice, juridical sentence and data regarding safety measures and biometric and genetic data are among the special quality data.  Sitorbis does not necessitate its customers/users to share any of the aforementioned special quality data in the process of accessing any of its services.  However Sitorbis may process the special quality data shared with the explicit consent of the customers/users, only for the corresponding purposes to provide better services. Furthermore, it takes the necessary measures for the processing of special quality data.

  Data obtained through the membership process

In the event of your membership to Sitorbis, the data you share for the process of membership is processed and stored in our systems. In the event of membership using Facebook, Google or other means of social media, the data which these means provide its partners, like your name, surname, profile picture and mail address, is accessed by and transferred to Sitorbis.

  Data processed with automatic systems

Sitorbis acts in compliance with the law on the protection of personal data, for data processed with automatic systems The information obtained from these data without the explicit consent of the persons cannot be used against them. However, Sitorbis may take decisions regarding the persons it will provide services for, using the data it has in its own system in line with the purposes of the firm.

Transfer of the personal data domestically and internationally

From your personal data, the part amounting to be sufficient for your accommodation to take place during the relevant events are shared with businesses that provide domestic and international accommodation.  Furthermore, to improve the overall service quality, Sitorbis reserves its right to share the necessary personal data, excluding data of special nature, with the solution partners with which it undertakes the relevant event. In addition, in an effort to increase the special interest tourism lobbies and types both in a domestic and global scope and both in public and private sector or to increase participation in the aforementioned type of tourism, Sitorbis can process personal data anonymously and use it as statistical data in accordance with the conditions in the present area.  The aforementioned use, in addition to including the direct exchange of statistics created on-demand with the relevant organization, can also include evaluation of the data within the body of Sitorbis and its exchange to the relevant organization as a service.

Rights on Relevant Personal Data

The owners of personal data have the right:

  • To be informed whether his/her personal data are processed or not,
  • To request information if the personal data are processed,
  • To learn the purpose of processing the personal data and whether the data are used for the corresponding purposes,
  • To get information on the third parties to whom the personal data are transferred in the country and abroad,
  • In case the personal data are processed incompletely or inaccurately, to request the correction and the notification of the third parties to whom the personal data are transferred.
  • Despite having been processed in accordance with the law no. 6698, to request the personal data to be deleted or removed within the framework of the conditions stipulated in article 7, in the event of the process of personal data is no longer required, and to request the notification of the third parties to whom the personal data are transferred.
  • To appeal to the negative results against himself/herself arising from the analysis of the data processed exclusively through the automatic systems,
  • In case the personal data are damaged due to the processing of the data contrary to the Law, to request that the damages are indemnified.

In the event of any request, arising in relation with the aforementioned rights, being conveyed to our firm in accordance with the ‘Rules and Procedures on Application to the Data Controller, Sitorbis will reply within the shortest time according to the content of the application within 30 days at the latest after the delivery to the firm, free of charge.  However, in the event of an additional cost for an application, Sitorbis can demand the sum which is indicated in the tariff created by the Personal Data Protection Authority.

Cookie Policy

What Are Cookies?

Cookies are small text files that are stored on your computer or mobile device when you visit a website. These files contain data such as your login information, your IP address and the pages you visit. Cookies enable the storage of your preferences, can keep your account logged in or can provide you with relevant content. You can obtain further information about cookies through www.aboutcookies.org and www.allaboutcookies.org.

Types of Cookies

Cookies can take different forms in relation to the duration in which they are stored in the devices or by whom they are added. In light of this information the main difference is as follows:

Session Cookies: These are temporary cookie files, which are erased when you close your internet browser.  The main purpose of the session cookies to help the website function in a proper manner.

Persistent Cookies: These files stay in one of your browser’s subfolders until you delete them manually or your browser deletes them based on the duration period contained within the persistent cookie’s file.

  First-party Cookies: First-party cookies are stored on the device by the domain (website) you are visiting directly.

  Third-party Cookies: Third-party cookies are created and stored on the device by domains other than the one you are visiting directly.

  How Can You Change Your Cookie Settings

By changing the preferences of the browser of your choice you can customize or cancel cookies altogether. The steps to be followed in order to manage cookie preferences in various web browsers can be accessed through websites below.

You can access detailed information on cookies we use on our website through our Cookies Policy.

       VI. Data of Our Employees

Processing of the data for business relations

Personal data of the employees may be processed without obtaining consent to the extent of requirements of health insurance and business relations. However, Sitorbis hereby undertakes the protection and confidentiality of the data of the employees.

Processing as per Legal Obligations

Sitorbis may also process the personal data of the employees without obtaining a separate consent to fulfill a legal obligation stipulated in the legislation or in case it’s explicitly specified in the legislation.  This case is limited to the obligations arising from the Law.

Processing in Favour of the Employees

Sitorbis may process personal data without obtaining consent for the procedures in favor of company employees like private health insurance. For the disputes arising from the business relations, Sitorbis may also process the data of the employees.

Processing of special quality data

Pursuant to the Law, race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothes, membership of an association, foundation or union, health, sexual choice, juridical sentence and data regarding safety measures and biometric and genetic data are among the special quality data.  The quality data obtained from the employees shall only be used for the corresponding purpose to allow the employees to benefit from health and insurance services and for ensuring the protection of Sitorbis. Quality data shall not be used by Sitorbis in any situation contrary to those above.   Besides the consent of the relevant person, Sitorbis also takes adequate measures determined by the Board for the processing of special quality data.

Data processed with automatic systems

The data processed regarding the employees with automatic systems may be used for in-house promotions and performance assessments.  The employees reserve the right to appeal to the results against them and they should perform this process in compliance with the internal procedures.  Appeals of the employees shall be evaluated again within the company.

Telecommunication and internet

The computers, telephone, e-mail and other applications allocated to the employees within the company shall only be used for business purposes. The employee cannot use any of these means allocated to himself/herself by the company for private purposes or communication. The company may control and monitor the data on these means.   The employee guarantees not to keep any data or information

apart from the business purposes on the computer, telephones or other means allocated to himself/herself as of his/her employment date.

       VII. Transfer of the Personal Data Domestically and Internationally

Personal data may be shared with business and solution partners to provide the services by Sitorbis.

       VIII. Rights of the Relevant Person

Sitorbis hereby agrees that the relevant person must provide his/her consent before processing the data within the scope of the Law and he/she reserves the right to determine the destiny of the data after the data is processed.

Regarding personal data  the relevant persons hold the right;

  1. To be informed whether his/her personal data are processed or not,
  2. To request information if the personal data are processed,
  3. To learn the purpose of processing the personal data and whether the data are used for the corresponding purposes,

To get information on the third parties to whom the personal data are transferred in the country and abroad,

  1. In case the personal data are processed incompletely or inaccurately, to request the correction,
  2. To request that personal data are deleted or removed within the framework of the conditions stipulated in article 7
  3. To request that the processes performed as per clause (d) and (e) are notified to the third parties to whom the personal data are transferred,
  4. To appeal to the negative results against himself/herself arising from the analysis of the data processed exclusively through the automatic systems, In case the personal data are damaged due to the processing of the data contrary to the Law, to request that the damages are indemnified. Nevertheless, the persons don’t reserve any right on the anonymized data within the company. Sitorbis may share the personal data as required by a juridical function or governmental authority as per the business and contractual relationship.

The owners of the personal data shall submit their requests regarding the above-mentioned rights to the contact address Yaşar Üniversitesi, Minerva Kuluçka Merkezi, No:37-39 Bornova / İzmir by completely filling out and putting their wet signatures on the application form given at www.sitorbis.com, the official website of the company, through registered letter with return receipt with the copies of their identity cards (only front page for birth certificate). The applications shall be replied within the shortest time according to the content of the application or within 30 days at the latest after the delivery to the company. You need to apply with a registered letter with a return receipt.  Besides, only the inquiries about you shall be replied and any applications made regarding your relative or friends shall not be accepted. Sitorbis may request further information and documents from the applicants.

       IX. Confidentiality Principle

The data of the employees and other persons within Sitorbis are confidential.  Nobody can use, copy, reproduce, transfer these data for other purposes apart from the business purposes.

    X. Process security

All necessary technical and administrative measures are taken to protect the personal data received by Sitorbis and to prevent the retention of them by unauthorized persons.  Within this framework, it’s ensured that the software complies with the standards, third parties are selected with care and data protection policy is followed within the company. Security measures that are taken by Sitorbis are constantly being upgraded and improved.

     IX. Inspection

Sitorbis carries out the necessary internal and external inspections for the protection of personal data.

       IIX. Notification of Violations

Sitorbis shall immediately act to remedy the violations in case a violation of personal data it stores in its body.  It shall mitigate or indemnify the damage of the relevant person.   In case the personal data are obtained by unauthorized persons, this case should be immediately notified to the Board of Personal Data Protection.

Notification on violations can also be made in accordance with the procedures indicated at http://sitorbis.com