We take your privacy seriously and are committed to safeguarding your personal information at MFY REAL ESTATE GAYRİMENKUL İNŞAAT VE TİCARET Inc. ("Royal White Property") (which term includes all subsidiaries of MFY REAL ESTATE GAYRİMENKUL İNŞAAT VE TİCARET Inc. ("Royal White Property" ). ("Company", "we" or "us" or "Royal White Property") values you as our guest, respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the sources of your personal data that we may collect from you or that you may provide to us and our practices for collecting, using, maintaining, protecting and disclosing that information.
WHAT INFORMATION WE COLLECT ABOUT YOU?
Personal information you give us
The information we collect on or through our platforms may include:
OTHER INFORMATION WE COLLECT
There is other information we may collect that does not directly reveal your specific identity or does not directly relate to you as an individual. We may automatically collect the following information when you use our service:
The information we collect automatically is statistical data. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:
The technologies we use for this automatic data collection may include:
INFORMATION WE RECEIVE FROM OTHERS
We work closely with third parties and receive information about you from them as well. We also collect personal information from individuals who may refer you as a friend to our loyalty schemes or products or services. We ask these individuals to confirm that you are happy to hear from us.
WHAT ARE THE SOURCES OF YOUR PERSONAL DATA?
The sources of your personal data collected (collectively referred as "Platforms" in this policy) may include without limitation the following
This policy does not apply to information collected:
WHY DO WE COLLECT AND HOW WE USE YOUR PERSONAL INFORMATION?
We use personal information for several legitimate interests, including to provide and improve our services, administer our relationship with you and our business.
To facilitate any reservation or booking requests we receive from you:
To facilitate a reservation or booking request we would need to collect and use the following personal information: name, email address, phone number, residential address, nationality, identification proof (such as Emirates ID or Passport) and credit card details. We would need to collect and use your personal information to fulfil our contractual obligations towards the service(s) requested by you (such as room booking, dining reservation, etc.).
In the event you have any special requests, we would need to collect additional personal information which may also include sensitive information. For example:
To manage your membership of our loyalty programs - 'U BY Royal White Property:
We encourage and invite you to join our loyalty program, so that they may benefit from exclusive offers, discounts, and promotions available to members. You may join our loyalty program by registering online on the 'U BY Royal White Property webpage - https://www.royalwhiteproperty.com
Once you register for our loyalty program, we would collect and process the following personal information: name, telephone number, email ID, 'U BY Royal White Property ID and transaction history. We would need to collect and use your personal information to fulfil our contractual obligations under the loyalty program.
As part of the loyalty program, we would also send our members information regarding special offers, discounts and promotions in pursuit of legitimate business interests. In the event you prefer not to receive such information, you may opt-out by following the instruction provided Section - "How to opt-out?".
To respond to any queries made by you:
We would need to collect and use the following personal information: name, email address, phone number, nationality and details of your enquiry.
In certain cases, your enquiry may relate to a specific service request, for example: requesting a copy of an invoice. For such requests, we need to use your personal information to help us respond to your request and to fulfil our contractual obligations under the requested service.
Additionally, when you call our customer service centre, we would maintain a record of the communications, including call recordings, in pursuit of our legitimate business interest to monitor and improve the quality of our guest support.
To provide you with information about Royal White Property’s services and latest offers:
It is in our legitimate business interests to send you information about Royal White Property's services and latest offers. We use your personal information such as email ID and/ or contact number to share information relating to Royal White Property's services and latest offers that may be of interest to you. In the event you prefer not to receive such information, you may opt-out by following the instruction provided Section - "How to opt-out?".
To personalize the information we send you:
We may combine the information we receive and collect about you to better understand your interests and preferences so that we can provide you with an experience that is tailored to those interests and preferences. For example, we may do this by offering you use of certain facilities (such as dining, spa or lifestyle events) that you are most likely to be interested in, or sending you personalized offers, discounts or promotions by email (where you have agreed to receive our emails), or advertising content that is relevant to your interests. In the event you prefer not to receive such information, you may opt out by following the instruction provided Section - "How to opt out?".
To enable you to avail special offers and benefits from our business partners:
We have strong and longstanding partnerships with business partners across sectors including Travel, Entertainment, and Lifestyle. Our partnerships allow you to avail special benefits and offers from our business partners. For example, Emirates Skyward members can avail Skywards Miles when they stay at our select hotels and resorts.
To help you avail of these benefits, we would need to collect and share the following personal information: name, Partner issued Membership ID and transaction history, with our business partners. We would need to collect and process your personal information to fulfil our contractual obligations towards our business partners and to ensure you avail the best of benefits and offers. To see more information about our current partnerships please visit our websites.
To request your feedback, and to respond to complaints:
Your satisfaction is our utmost priority and we proactively take necessary steps to ensure you are well satisfied with our services.
To help us respond to your feedback or complaints, we would need to collect the following personal information: name, email ID, transaction details (such as Royal White Property hotel and room type you stayed at) and your feedback/ complaints in the submission form or through a survey after a hotel stay or dining experience.
We collect and use your personal information in pursuit of our legitimate business interests to address your concerns and to take necessary steps towards continual improvement. In the event you prefer not to receive such information, you may opt out by following the instruction provided Section - "How to opt out?".
To establish a working relationship with corporate clients:
We collect/ receive personal information about you through one of the following channels:
We would need to collect the following personal information: name, email ID, contact number, designation, and the company you represent. We use this information for the purposes, listed below, in pursuit of our legitimate business:
To enter into, renew or fulfil service contracts with our corporate clients:
Over the years we have established a strong working relationship with many corporate companies to facilitate group bookings, reservations, and events. To facilitate our service offerings with our corporate clients, we enter into contractual agreements that require us to collect personal information of the company representatives, such as name, email ID, designation, and the company you represent.
To facilitate email campaigns carried out by our sales and marketing departments:
As part of our email campaigns, we track whenever you receive, open, click a link, or download any attachments from an e-mail you receive from Royal White Property. We will carry out automated profiling of such information to evaluate your interest in our service offerings or promotions. This processing will enable us to identify and target potential guests or business partners, tailor our marketing and provide you with relevant and timely content based on your interests, in pursuit of our legitimate business interests. In the event you prefer not to receive such information, you may opt out by following the instruction provided Section - "How to opt out?".
To comply with legal requirements and exercise or defend legal claims:
We may need to process and retain your personal information to comply with legal requirements to which we are subject (for example in relation to health and safety). It is in our legitimate interests to process personal information for the purposes of exercising and defending legal claims. Processing personal information may also be necessary to ensure compliance with the relevant legal and regulatory obligations.
To process your payments and protect against fraudulent transactions:
We may need to process your personal information to keep your payments safe and secure and protect against fraudulent transactions. It is in our legitimate interests to process personal information to keep your payments secure and to prevent fraud. Processing personal information in this way may also be necessary to ensure compliance with the relevant legal and regulatory obligations.
To comply with any opt-out or do not disturb requests we receive from you:
We understand that you may not prefer for us to contact you with any offers, promotions or details of our products and services. In the event you opt-out, we may be required to maintain information such as name, email ID/contact number and the subscription(s) that you have opted out of to ensure compliance with your requests. Also, in the future, if you wish to hear from us, you may at any time, contact us to opt-in and we would happy to keep you posted about our latest offers, promotions and/ or details of our products and services.
HOW TO OPT OUT?
WHO MIGHT WE SHARE THIS INFORMATION WITH?
If you would like more information on protection measures and transfer mechanisms, please contact us using the details provided in Section - 'How do you contact us?'.
HOW LONG DO WE KEEP INFORMATION ABOUT YOU?
We will only keep your personal information for as long as is reasonably necessary taking into consideration our need to answer queries or resolve problems, any other purpose outlined above or to comply with legal requirements under applicable law(s). This means that we may retain your personal information for a reasonable period, for example, the end of the contract with the guests you represent, or after your query has been addressed. In certain cases, we may retain your personal information for a longer period where extended retention periods are required by law or regulation and to establish, exercise or defend our legal rights. We will ensure that it is disposed in a secure manner when it's no longer needed.
For more information on where and how long your personal information is stored, and for more information on your rights of erasure and portability, please contact us using the details provided in Section - 'How do you contact us?'.
HOW SECURE IS YOUR INFORMATION?
Your personal data security is an important concern to us. We provide the utmost care in secure transmission of your personal information from your computer, smartphone, and other electronic devices to our servers. We use industry security standards to safeguard the confidentiality of your information (e.g. firewalls, Transport Security Layer ("TLS") etc.) and to make sure that your personal information is secure with us.
We have implemented and maintains appropriate technical and organizational security measures, policies and procedures to protect your personal information from the accidental loss, unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All payment transactions are encrypted using TLS technology. Ex: Measures we take includes:
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
WHAT ARE YOUR RIGHTS?
If you are subject to laws that provide you with such rights, you may have certain rights in relation to your personal information given below.
If you wish to access any of these rights, we may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for example, if your request is manifestly unfounded or excessive.
If you would like to access the below rights, you may contact us by completing a form on our website or by mailing us at email@example.com or sending us a communication to Data Privacy Office. We shall aim to comply with all requests within reasonable time in-line with applicable laws. We may not always be able to fully address your request, for example,
We will make every reasonable effort to honour your request in-line with applicable laws. In the event we require additional time due to the complexity of the request, we shall promptly inform you of the same.
The right to access
You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us, and obtain certain other information about how and why we process your personal data (like the information provided in this privacy statement).
The right to rectification
You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.
The right to restrict processing of personal data
You have the right to restrict our processing of your personal data in the following cases:
We can continue to use your personal information following a request for restriction, where:
The right to erasure (also known as 'the right to be forgotten')
You have the right to obtain deletion of your personal data in the following cases:
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
The right to object to the processing of personal data
You have the right to object to our processing of your personal data in the following cases:
The right to data portability
You have the right to receive your personal data provided to us and have the right to send the data to another organization (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.
The right to withdraw consent at any time (where processing is based on consent)
Where we process personal data based on consent, individuals have a right to withdraw consent at any time.
The right to lodge a complaint with a supervisory authority
If you are not content with how we manage your personal information, you can lodge a complaint with a supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred within the EEA. We sincerely hope that you will never need to, but if you do want to complain about our use of personal data, you can contact us in one of the ways mentioned in Section - 'How do you contact us?'. We will look into and respond to any complaints we receive.
UPDATES ON POLICY
This policy may change from time to time. Your continued use of our platforms after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
HOW DO YOU CONTACT US?
In case of any queries related to this policy, you can contact our Data Privacy Office in one of the following ways.
Send us a communication to the Data Privacy Office, MFY REAL ESTATE GAYRİMENKUL İNŞAAT VE TİCARET Inc. (“Royal White Property”) , PO Box 34485, Istanbul, Turkey.