PRIVACY POLICY FOR THE WEBSITE

1. DEFINITION OF CONCEPTS

"Law" means the Federal Law of the Russian Federation "On Personal Data" with all amendments and additions, as well as other legislative acts of the Russian Federation.

"Controller" means the person who is responsible for the processing and protection of Personal Data of Users located within the EU within the meaning of the General Data Protection Regulation of 27 April 2016 (the "GDRP").

"Site" means a unit of information on the Internet, a resource of web pages (documents) that are united by a common theme and linked to each other through links. It is registered to the Right Holder and is necessarily linked to a specific domain, which is its address. This Policy is developed for the following website: artalanya.com

"Personal Data" means the aggregate of personal data and/or non-personalized information about the User provided by the User to the Rights Holder and/or automatically collected by the Rights Holder and/or third parties.

"Policy" means this Website Privacy Policy (as it may be amended).

"User" means a legal or natural person who uses and/or accesses the Site from a device.

"User Agreement" means the agreement entered into between the Right Holder and the User regarding the procedure, rules and features of using the Website. The User accedes to such agreement and has no right to make and/or demand any changes or additions to it. The User can read the terms of the User Agreement at the following link: http://artalanya.com/politika.

"Copyright Holder" means the following person in whose name the Site is registered:

ART ALANYA GAYRİMENKUL TURİZM TİCARET LİMİTED ŞİRKETİ

"Cookies" means small files sent by a site and placed on User's computers, smartphones, tablets, watches and other mobile devices to improve the performance of the sites as well as the quality of the content posted therein.

2. RELATIONS COVERED BY THE POLICY

General provisions

This Policy is used and applies solely to Personal Information received from a User in connection with their use of the Site. The provisions of this Policy are intended to:

(1) determining the types and types of Personal Data obtained, the uses and purposes for which Personal Data are used (processed), and the sources from which such Personal Data are obtained; and

(2) defining the User's rights regarding the protection of the confidentiality of the Personal Data transmitted by the User; and

(3) determination of the persons responsible for the processing and storage of Personal Data, as well as of the third parties to whom such data are disclosed (in whole or in part).

The rules of this Policy do not apply if third parties process Personal Data that is voluntarily provided by the User.

By using the Site, the User agrees to the terms of this Policy and gives its consent to the Right Holder to collect, process, retain and store Personal Data in the manner and on the terms set forth in this Policy.

If the User does not agree with the terms of the Policy and/or certain terms of the Policy are not clear to him, in this case, the User must immediately stop using the Site.

User rights to protect personal data

In connection with the provision of Personal Data, the User automatically receives the following rights:

(1) to obtain data concerning their processing (grounds and purposes of such processing, the methods of processing used, information on the persons who have access to them or to whom they may be disclosed on the basis of a contract or the Act).

(2) obtain data on the location and identity of the persons processing Personal Data.

(3) obtain data on the retention period of Personal Data.

(4) to obtain data on the performed or suspected cross-border transfer of Personal Data.

(5) appeal actions or omissions of the Rights Holder to the authorized body for the protection of the rights of subjects of personal data or in court.

(6) receive damages and/or compensation for moral damages in court as a result of violations of the User's rights to protection and defense of his Personal Data committed by the Licensor and/or third parties.

(7) exercise other rights in the field of personal data protection, as provided by law or the provisions of this Policy.

3. LIST OF PERSONAL DATA TO BE COLLECTED

Non-personalized user information

The Copyright Holder may automatically collect and process the following non-personalized information about the User in connection with the use of the Site:

(1) information about traffic, possible number of clicks, logs and other data.

(2) information about the User's location (geolocation). The User may disable geolocation at any time by changing the appropriate browser settings. Geolocation is used by the Site only when the User is actively using it. Geolocation ceases to function when the User exits the browser.

(3) information about the device (identification number of the device from which you log in, operating system, platform, browser type and other browser information, IP address).

Personal information about users

The User provides the Right Holder with the following personal information about himself:

(1) the full surname, first name, and patronymic.

(2) date of birth and age.

(3) email address.

(4) a cell phone number.

(5) data contained in the User's personal account (profile), all internal correspondence of the User (if any), as well as other activity of the User's personal account (profile).

(6) data on orders placed and/or services received/paid for through the Site.

(7) a record of all postings by User on the Site, including, but not limited to, comments, ratings, reviews, reports, videos and photos, likes, ratings and/or any other forms of activity available to User on the Site and/or the content created.

(8) data and information obtained as a result of combining those or other Personal Data of a particular User, as well as data and information obtained about the User from third parties (partners, marketers, researchers).

The user is the sole person responsible for the completeness of the provided personal (personal) data and is obliged to make timely changes (update, verification, correction) on a regular basis.

The copyright holder assumes that all personal (personal) data provided by the User is reliable and that the User keeps such information up to date.

Using Captcha

The Site integrates Captcha, which is a type of Cookie, the purpose of which in this case is (1) to protect the User from possible spam from third parties on the Internet, as well as from other irrelevant and/or prohibited content, and (2) to identify the User to distinguish it from bots / robots, and (3) to improve the User's ability to use the content of the Site.

Logging in allows Captcha to automatically access and collect the following information:

(1) Cookies installed on your browser within the last six (6) months; and/or

(2) the number of clicks made by the User; and/or

(3) information about the stylization of the web page; and/or

(4) browser language settings; and/or

(5) plug-ins installed in the User's browser; and/or

(6) all Javascript objects.

Information about transactions in progress

The user can make payments for goods or services through the Site by entering in a special field the information about the payment card and the identification data of the owner of such a card. The user can make payments as follows: ________.

User data in this case is collected and processed solely for the purposes of payment, fraud prevention, and compliance with other requirements of the Act.

The User consents to access and collection of such Personal Data by the Rights Holder and the relevant payment system or banking institution through which the payment is made, and agrees to the privacy policy of the relevant payment system or banking institution.

Using cookies

The Site uses certain Cookies to store the IP address, User preferences, or the type of device used in order to (1) keep statistics on visits and traffic to the Site, and (2) personalize the data displayed to the User, and (3) store data needed to identify the User, including when accessed from different devices, and (4) display ads according to the interests and preferences of the User. The Site may use both the Right Holder's own Cookies and third-party Cookies.

The site uses the following Cookies:

(1) Technical (functional) Cookies, which are necessary to control traffic and data transmission, to identify Users and provide access to the content of the User and without which the use of the Site is functionally restricted, as well as to prevent the provision of recommendations that are not in the interests of the User.

(2) Statistical Cookies, which are needed to track the frequency of visits to the Site, how Users use the Site and/or its content, identify the type and type of content that is popular or of interest to Users.

(3) Geolocation Cookies, which are used to determine the User's location in order to personalize the content displayed on their device.

(4) Advertising (marketing) Cookies, which are needed to place advertising and/or marketing advertisements that match the User's preferences and interests.

(5) Third-party cookies, which are set by third parties with the User's permission and are intended for statistical research regarding the User's behavior on the Internet and/or sending personalized advertising or marketing materials to the User and/or providing goods or services.

The User has the right to disable cookies at any time by changing certain settings in their browser. Such disabling shall not limit or change the User's access to the functionality and/or content of the Site. To disable Cookie Files, you must perform the following actions:

Open the browser on your device, go to "Settings", select "Cookies", change the settings to your desired configuration.

4. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA

Defining processing goals

Personal Data is collected and processed for the following purposes:

(1) to analyze User behavior and identify User preferences for certain types of content.

(2) for the prompt and correct operation of the Site, to improve its functionality and content.

(3) to identify the User.

(4) to provide personalized advertising and marketing materials.

(5) to send personalized advertising and marketing materials to the specified email address and/or cell phone of the User.

(6) to comply with the requirements of the Act.

(7) to track orders made by the User through the Site.

(8) to determine the location of the User.

(9) for technical support of the Site, identification of problems in its operation and their elimination.

(10) to communicate with the User (communication).

(11) to fulfill other obligations of the Rights Holder that have arisen to the User.

(12) for statistical studies.

(13) for any other purpose, subject to the separate consent of the User.

Processing of Personal Data shall be based on the principles of: (1) lawfulness of the purposes and methods of processing; and (2) good faith; and (3) compliance of the purposes of Personal Data processing with the purposes predetermined and stated when collecting such Personal Data; and (4) compliance of the amount and nature of Personal Data processed with the stated purposes of their processing.

Terms of personal data processing

Processing of Personal Data shall be carried out when: (1) obtaining consent from the User; or (2) achieving the Right Holder's goals under an international treaty or the Law; or (3) providing the User's Personal Data to an unlimited number of people; or (4) performing other obligations of the Right Holder to the User, including but not limited to providing certain content to the User; or (5) saving the User's life or health when consent to processing their Personal Data cannot be obtained in advance.

In the case of depersonalization of Personal Data, which does not directly or indirectly identify the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy no longer apply to them.

The Rights Holder shall take all possible measures to protect the confidentiality of Personal Data received, except in cases where the User has made such data publicly available.

Processing of Personal Data shall be carried out with or without the use of automated means.

5. THIRD PARTY ACCESS TO PERSONAL DATA

Disclosure of personal data to third parties

The Rights Holder has the right to disclose Personal Data (1) to its affiliates, branches and representative offices, opened both in the Russian Federation and in other countries; (2) to successors of the Rights Holder, which arose from its liquidation, reorganization or bankruptcy, and which obtained exclusive rights to the Site; (3) to providers of payment services or banking (financial) institutions, for transactions of the User through the Site; (4) to third parties exclusively for the purpose of providing

The Rights Holder discloses Personal Data only if (1) it is confident that third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data as the Rights Holder itself takes, and (2) consent to such disclosure has been previously expressed by the User and/or is permitted under the Law.

Advertising from third parties

The Site may contain advertising banners and/or links to third-party sites. The User's use of such sites (by clicking on a link or by any other means) may entail the collection, processing and use of Personal Data, as well as the possible automatic transfer of Cookies to the User's device from which the User is transferred to a third-party site. The Rights Holder is not responsible for the ways, methods and procedures of processing of Personal Data by third-party websites. Consequently, the Rights Holder is also not responsible in case of disclosure of Personal Data to the public in connection with the User's use of such websites.

The Copyright Holder strongly recommends that each User read in detail the personal data protection policies of the sites used.

The User may at any time disable such advertising banners and/or links on the Site by doing the following:

Go to the settings in myAlpari, find the "promotional materials" option and uncheck it.

6. ADVERTISING PLACEMENT

Advertising on the Site

The Rights Holder, along with the content, places various advertising and marketing materials on the Site, taking into account the User's identified preferences for this or that content. Placement of advertisements involves the installation of certain Cookies on the Rights Holder's device.

The user has the right to reject such advertising at any time by performing the following actions:

Go to the settings in myAlpari, find the "promotional materials" option and uncheck it.

Sending out promotional materials

The User agrees with the Right Holder's right to send personalized advertising and marketing materials to the provided email address and/or cell phone.

The user has the right to opt out of receiving such advertising and marketing materials at any time by doing the following:

Click the unsubscribe button in the email or send an unsubscribe email to info@artalanya.com

Please note that in case of refusal to receive advertising and marketing materials, the User may continue to receive any notices from the Right Holder related to the manner of use of the Website and/or its content.

7. SUBMITTING COMPLAINTS AND INQUIRIES TO THE RIGHT HOLDER

Request to stop processing of personal data

Each User has the right to object to the Right Holder's processing and/or storage of their Personal Data. Such an objection may be expressed as follows:

The request should be sent to the Right Holder at info@artalanya.com

Request for information on personal data

If the User has any questions related to the manner of application or use of this Policy, the manner and/or method of processing of Personal Data, the User may ask such question as follows:

The question should be sent to the Rights Holder at info@artalanya.com

Change (update, addition, correction) or deletion of personal data

The User has the right to change or delete their Personal Data at any time on their own, unless such change or deletion could lead (1) to a violation of the rules of this Policy; or (2) to a violation of the Law; or (3) the nature of such Personal Data is evidence in any litigation arising between the Rights Holder and the User. This requires the User to delete their personal account (profile) on the Site.

The Rights Holder has the right to delete the User's personal account/profile as well as all Personal Data about the User at any time, if the User has violated the terms of this Policy and/or the User Agreement.

If Personal Information about the User is deleted, all publications made by such User (comments, rating, feedback, publication of reports, videos and photos, likes, ratings) and/or any other forms of activity available to the User on the Site shall also be automatically deleted.

8. TERMS AND PROCEDURE OF STORAGE OF PERSONAL DATA

Storage is carried out independently by the Rights Holder.

Storage is carried out for the duration of the User's use of the Site.

9. MINORS' ACCESS TO THE SITE

Users in the Russian Federation

Use of the Site is intended for individuals over the age of 18 years who can access it only if they have provided prior consent to the processing of their Personal Data. The Rights Holder verifies the User's age as follows:

The user will need to enter his date of birth in a special field.

If the User is a minor, he/she must immediately stop using the Site.

Users in the European Union

Use of the Site is intended for persons aged 16 years and older who can access it only if they have provided prior consent to the processing of their Personal Data. The Rights Holder verifies the User's age as follows:

The user will need to enter his date of birth in a special field.

If the Copyright Holder becomes aware that the User's age does not correspond to the permissible age for using the Website, in such a case the Copyright Holder shall immediately block access of such User to the Website.

10. PROCEDURE FOR PROTECTION OF PERSONAL DATA

Protection of confidentiality of Personal Data is the primary and important task for the Rights Holder. The Rights Holder adheres to all required international standards, rules and recommendations for the protection of Personal Data.

The right holder has implemented a number of technical and organizational methods to protect Personal Data from disclosure or unauthorized access by third parties.

11. USERS LOCATED IN THE EUROPEAN UNION

General provisions

Since the Site is accessible to users from the European Union, the Copyright Holder is additionally obliged to adhere to the GDRP provisions.

The controller within the meaning of this Policy is the Rights Holder.

The Right Holder shall store Personal Data for a reasonable period of time necessary to achieve the purposes of processing, but not less than the period prescribed by the local legislation of the Member State of the European Union, on whose territory the Site is available, for the storage of a particular type of Personal Data. Upon expiry of the time period established for storage, the Right Holder undertakes to immediately destroy or anonymize such data.

Official representative

Since the Controller is located outside the territory of the European Union, the following person is designated as its official representative for the protection of Personal Data of Users in the European Union: ________, address: ________, contact details: ________.

User rights in the field of personal data protection

Under Chapter 3 of the GDRP, users within the European Union have the following rights with respect to the protection of Personal Data: (1) the right to be informed of their Personal Data ("the right to be informed"); and (2) the right of access to their Personal Data ("the right of access"); and (3) the right to rectification of Personal Data ("the right to rectification"); (4) the right to erasure of Personal Data ("the right to erasure"); and (5) the right to restrict processing of Personal Data ("the right to restrict processing"); and (6) the right to transfer Personal Data to third parties ("the right to data portability"); and (7) the right to object ("the right to object").

12. FINAL PROVISIONS

Availability of the text of the policy for review

Users can read the terms of this Policy at the following link: http://artalanya.com/politika.

This Policy may be translated into a foreign language for those Users who access the Site outside of the Russian Federation. In the event of a discrepancy between the text of the original (Russian) and its translation, the original language shall prevail.

This revision of the Policy is effective as of November 1, 2022.

Policy changes and additions

This Policy may be amended from time to time. The Rights Holder shall not be liable in any way to the User for changing the terms of this Policy without the User's permission and/or consent.

The User undertakes to check the provisions of this Policy on a regular basis for possible changes or additions.

Applicable law

This Policy was developed in accordance with the current legislation on personal data protection of the Russian Federation, in particular the provisions of the Federal Law of July 27, 2006 № 152-FZ "On Personal Data" (with all additions and amendments), the Federal Law of July 21, 2014 № 242-FZ "On Amendments to Certain Legislative Acts of the Russian Federation in terms of clarifying the order of processing personal data in information and telecommunications networks" (with all additions and amendments), as well as the provisions of the General Regulations

Risk of disclosure

Regardless of the measures taken by the Rights Holder to protect the confidentiality of personal data received, the User is hereby deemed to be duly informed that any transmission of Personal Data on the Internet cannot be guaranteed to be secure, and therefore the User makes such a transmission at its own risk.

Public information

The User shall have the right to publish and post any content at his/her own discretion and in any of the available forms (photo, video, comment, article, evaluation, blog, etc) on the Site. Such publications and content shall be publicly available to other users, and therefore the Licensor shall not undertake any obligation to protect any Personal Data which may be disclosed or published as part of such publication and/or content.