This text is a draft prepared in line with common industry practice; a legal review is recommended before publication.
1. Data controller
Under the Law No. 6698 on the Protection of Personal Data (“KVKK”), your personal data are processed by Karinna Ski School (the “School”), in its capacity as data controller, within the scope described below.
Address: Karinna Hotel, Uludağ 2nd Development Zone, Bursa, Turkey · Email: info@karinnakayakokulu.com · Phone: 0224 285 23 31
2. Personal data processed
- Identity: first name, last name
- Contact: phone number, email address
- Customer transaction: lesson type, level, number of people, preferred lesson date and time, instructor preference, booking requests, lesson and rental records, requests and complaints
- Transaction security: IP address, form submission time, cookie records
- Finance: information required to collect lesson and rental fees
3. Purposes of processing
- Receiving and evaluating your booking and contact requests, and responding to you
- Planning lessons, determining instructor and time availability, and providing lesson and rental services
- Carrying out pricing, payment collection and accounting processes
- Managing requests, suggestions and complaints, and measuring service quality
- Ensuring the security of the website and preventing misuse
- Fulfilling legal obligations and responding to requests from competent authorities
4. Legal grounds
Your personal data are processed on the legal grounds set out in Article 5(2) of the KVKK, namely that processing is directly related to the conclusion or performance of a contract (c), is necessary for the data controller to fulfill its legal obligation (ç), is necessary for the establishment, exercise or protection of a right (e), and is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject (f). Analytics cookies and, where applicable, the sending of commercial electronic messages are based solely on your explicit consent.
5. Method of collection
Your personal data are collected through the booking request and contact forms on our website, by phone, WhatsApp and email, and in face-to-face meetings, by partly automated and non-automated means. Information entered in the booking request form is transferred to our school management system, where lessons are scheduled.
6. Transfers
Limited to the purposes stated above, your personal data may be transferred to the persons from whom we obtain accounting and financial advisory services, to hosting and email service providers, to lawyers in the event of legal disputes, and to public institutions and organizations authorized by law. If you contact us via WhatsApp, the information you share is transmitted through the servers of that application; your choice of this means of communication constitutes your explicit consent to this transfer. If you consent to analytics cookies, website usage data may be processed abroad as part of the Google Analytics service.
7. Retention period
Your personal data are retained for the period required by the purpose of processing and prescribed by the applicable legislation; at the end of that period, they are erased, destroyed or anonymized. Booking requests that do not result in a lesson are retained for a maximum of two years.
8. Your rights
Under Article 11 of the KVKK, you have the right to learn whether your personal data are being processed; to request information if they have been processed; to learn the purpose of the processing and whether the data are used in line with that purpose; to know the third parties in Turkey or abroad to whom your data are transferred; to request rectification if your data are incomplete or inaccurately processed; to request the erasure or destruction of your data under the conditions set out in the KVKK; to request that these operations be notified to the third parties to whom your data have been transferred; to object to any outcome to your detriment arising from the analysis of your data exclusively by automated systems; and to claim compensation for damages if you suffer harm as a result of unlawful processing.
9. Applications
You may submit your requests regarding your rights in writing to our address above, together with information that verifies your identity, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, or send them by email to info@karinnakayakokulu.com. Your application will be concluded free of charge within thirty days at the latest, depending on its nature.