Personal Data

In accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK” – Turkish Personal Data Protection Law), Dijital Otel Yönetim Bilişim Sistemleri A.Ş. (Europrotel) places great importance on protecting the personal data of our customers, website visitors, and other individuals with whom we maintain business relationships. This document outlines Europrotel’s policy and practices regarding the protection and processing of personal data.

Identity of the Data Controller

Pursuant to KVKK, the “Data Controller” is the legal entity that determines the purposes and means of processing personal data. In this context, the data controller is:

Dijital Otel Yönetim Bilişim Sistemleri A.Ş.
Address: Kültür Mah, Şevket Özçelik Sk. No:30/6 Erel Apartmanı, Alsancak/İZMİR, Türkiye
Phone: +90 212 347 8052 | +90 232 463 7920
Email: bilgi@www.europrotel.com

As the data controller, Europrotel declares that it processes your personal data in accordance with KVKK and relevant legislation.

Purposes of Personal Data Processing

Personal data collected by Europrotel may be processed for the following purposes:

• Service and Operational Purposes: Carrying out necessary operational activities within the scope of software rental, analytics, training, and consultancy services provided by Europrotel. For example, using identity and contact information for customer registration, service delivery, and technical support.
• Support and Communication: Receiving, evaluating, and responding to support requests or demo inquiries submitted through our website. Communication is established via phone, email, or online meetings to provide assistance. Contact and request-related data are processed for resolving issues or conducting demos.
• Customer Relationship Management: Managing relations with current or potential customers, monitoring and enhancing customer satisfaction (e.g., measuring service quality, conducting surveys, or requesting feedback).
• Marketing and Promotion: With your explicit consent, conducting marketing activities for Europrotel’s products and services, sharing announcements and promotions. You may receive newsletters or calls. Such activities require your prior consent and can be opted out at any time.
• Legal Compliance: Providing required information to competent authorities as mandated by law (e.g., keeping certain records, retaining invoices, responding to official inquiries).
• Internal Auditing and Reporting: Conducting internal reports, audits, and analytics to improve service quality and operational efficiency. Anonymized data may be used for statistics; personal data may be reviewed in internal investigations if necessary.
• Security: Ensuring the security of Europrotel’s offices, information systems, and website. This includes camera surveillance at physical locations, logging website access, and recording phone calls for quality and legal purposes (see below “Recording of Phone Calls”).

Recording of Phone Calls

When calling Europrotel’s support or general contact lines, your phone conversations may be recorded for the following purposes:

• Improving service quality and training purposes,
• Using recordings as evidence in case of disputes,
• Conducting internal audits and control processes,
• Fulfilling legal obligations as required.

Call recordings are stored securely in line with confidentiality principles and can only be accessed by authorized personnel. They are retained for the necessary duration (typically 2 years from the recording date) and deleted or anonymized afterward. You will hear an announcement before the call begins informing you of the recording, in compliance with Article 10 of KVKK.

Categories of Processed Personal Data

Europrotel processes various categories of personal data in line with the purposes stated above:

• Identity Information: Name, surname, ID number, passport number, etc. (usually required for contracts or invoicing).
• Contact Information: Phone number, email address, home or work address – used for communication and support activities.
• Customer Transaction Data: Service usage details, support or complaint records, demo requests, order and billing data.
• Security Information: Website access logs, IP addresses, session cookies, passwords – processed to maintain system security.
• Visual and Audio Records: CCTV footage at offices and phone call recordings – retained strictly for security and quality purposes.
• Employment and Professional Data (in limited cases): Job titles, work history of job applicants or business contacts, processed for communication and evaluation purposes.

Sensitive personal data (such as religion, health data, biometrics) is not collected by Europrotel and users are advised not to provide such information. Data is collected only as needed and relevant to our operations.

Transfer of Personal Data

Europrotel complies with the principles of KVKK in personal data transfers. Personal data is not shared with third parties except in the following cases:

• Service Providers and Affiliates: Data may be shared with service providers (e.g., hosting, storage, technical support) and Europrotel group companies where necessary, under confidentiality agreements.
• Legal Requirements: Data may be shared with authorized public bodies if required by law or legal process (e.g., court orders, regulatory requests).
• Business Transfer: In the event of a merger, acquisition, or asset transfer, personal data may be transferred to the new entity, ensuring equivalent data protection.

Currently, Europrotel does not transfer personal data abroad. If foreign servers or international partners are used in the future, international transfers will only occur in compliance with Article 9 of KVKK and with proper safeguards.

Method and Legal Basis of Data Collection

Methods: Your personal data may be collected through:

• Online forms on our website (contact, support, demo, etc.),
• Verbal communication via phone calls,
• Printed contracts, offers, or order forms,
• Emails, written correspondence, or business cards,
• Camera recordings when visiting our offices,

Data may be collected directly from you or the organizations you represent.

Legal Basis: Your personal data is processed under the legal grounds outlined in Articles 5 and 6 of KVKK:

• Legal Obligation: Required data processing under laws (e.g., billing information under tax law).
• Contract Performance: Data required for signing or fulfilling contracts (e.g., registering customers for software rental).
• Explicit Consent: For marketing and newsletters, your prior consent will be requested. You may withdraw your consent at any time.
• Legal Requirements: Data may be processed when legally required (e.g., providing logs to legal authorities).
• Legitimate Interest: Data may be processed for Europrotel’s legitimate interests without violating your fundamental rights (e.g., recording calls for quality monitoring).

In all cases, data is collected and processed in a limited and proportionate manner. Unnecessary or unrelated data processing is strictly avoided.

Rights of the Data Subject

Under Article 11 of KVKK, data subjects have the following rights:

1. To learn whether personal data is being processed,
2. To request information if data has been processed,
3. To learn the purpose of processing and whether it is used accordingly,
4. To know the third parties to whom data is transferred domestically or abroad,
5. To request correction if data is incomplete or incorrect,
6. To request deletion or destruction of data under Article 7,
7. To request notification of these changes to third parties,
8. To object to any outcome arising from automatic processing,
9. To request compensation if they suffer damages due to unlawful data processing.

How to Exercise Your Rights

You can submit your requests in writing to Europrotel using one of the following methods, including your identification and relevant explanations:

• By Mail: Send a signed letter with a copy of your ID to our Istanbul office (Trump Towers, Kuştepe Mah. Mecidiyeköy Yolu Cad. No:12 Tower 2 Floor:18, Şişli/İstanbul) via registered mail. Write “KVKK Information Request” on the envelope.
• By Email: You may send your request from your registered email (KEP) address to our official KEP address or from your email registered with us to bilgi@europrotel.com. Include “KVKK Information Request” in the subject line.
• In Person: Visit our office with valid ID and hand-deliver your request. You will be provided with a receipt confirming your application.

Europrotel will respond to your request free of charge and within a maximum of 30 days as per Article 13 of KVKK. We may require identity verification before fulfilling your request and may ask for additional information if necessary.

If your request is accepted, it will be fulfilled. If it is rejected, a reasoned explanation will be provided. If there are additional costs (except where Europrotel is at fault), fees may be charged according to the tariff set by the Data Protection Authority.

For more information, please also review our Privacy Notice. Europrotel continues to take all necessary administrative and technical measures to ensure full compliance with KVKK.