LAST UPDATED 1 APRIL, 2020
Karpaz Gate Marina Limited, together with our holding company(ies), (together, “KGM”, “we” or “our”), respect the privacy of every individual who visits KGM and/or uses our website.
is provided to us when you stay or travel with us (or make enquiries to stay or travel with us) either by you or by a third party through whom you have made an enquiry or booking; and
we collect from you when you visit our website or which we obtain from any communications with you.
1. Data Controller
2. Personal data we collect
3. Use of personal data
4. Sharing personal data
5. Your rights
6. Data transfers
7. How we protect your personal data
8. How long we keep personal data for
9. Links to other website
12. How to Contact Us
2.1 Personal data you provide on a voluntary basis
We will collect, store and process information about you if you voluntarily provide us with such information in connection with the following:
filling in a form on our website;
filling in a physical registration card;
opting in to receive marketing information with us;
creating an on-line account with us and managing your preferences;
contacting us by telephone or face to face (e.g. in the context of making a reservation);
sending us a letter, e-mail or social media message;
subscribing to receive a service from us (e.g. a newsletter, blog or by following us on social media);
requesting promotional information from us (e.g. information about any of our goods or services including KGM gift cards);
participating in a survey, competition or prize draw; or
contributing content to us (e.g. for display on a KGM blog).
The types of information we may obtain include:
passport and visa data, payment data, travel history and details of joint travelers;
dates of your stay or travel with us and associated charges;
purchase or delivery of products or services;
reviews and opinions about our brand, products and services;
information we receive about you from any third parties through whom you have booked your arrangements; and
information we receive about you from other members of the KGM Group (which may include information relating to travel dates, details of payments made to us, special requests and other information relating to your personal preferences (e.g. food and beverage preferences and interests).
2.2 ‘Special category’ personal data
We do not collect data which is, by its nature, particularly sensitive (e.g. genetic data, biometric data, data revealing racial or ethnic origin, political opinions, sex life, sexual orientation, religion or other beliefs, data concerning health, criminal background or trade union membership) unless it is volunteered by you.
We may use certain sensitive (or “special category”) personal data where you have given your explicit consent to us doing so, to better serve and meet your needs. Such sensitive data is only shared with other members of the KGM Group or our third party service providers acting as data processors (e.g. excursion providers, restaurants, transport providers) for the purpose of providing the services you request and will not be shared or used by us for any other purposes.
Examples of sensitive personal data we may collect and process include:
dietary requirements which may imply or suggest your religion, health or other sensitive personal data;
2.3 Personal data we collect automatically
When you visit a KGM website, we may also collect certain data through the use of “cookies” and other automated means. Cookies are small pieces of data that are stored by your browser on your computer’s hard drive. Such data may comprise the following data:
date and time;
originating IP address;
type of browser and operating system used (if provided by the browser);
URL of the referring page (if provided by the browser);
completion status of the request;
geographic location; or
To learn more about cookies, how they are used and how to exercise your choice with respect to their collection of information on this site, please click here.
As a provider of luxury hospitality establishment, KGM has a legitimate business interest in operating and improving its business and the services it offers. KGM therefore uses and processes your personal data to:
help us create content that is relevant to our visitors;
make improvements to our website and social media pages and ensure that content on these is presented in the most effective manner for you;
provide you with information, products or services that you request from us or which we feel may interest you;
facilitate bookings, payment and other administrative processes related to your stay or travel;
assess and help us understand general trends and patterns relating to our business;
provide for the safety and security of our guests and visitors;
manage general record keeping;
enable us to compile anonymous, aggregated statistics that allow us to understand how users use our website and to help us improve the structure of our website;
enable you to make reservations, buy KGM gift cards and payments;
meet any legal and/or regulatory requirements;
provide the products or services you request from us including providing personalized services; and
improve our products and services and to ensure our products and services are of interest to you.
Even where KGM has a legitimate interest in processing your personal data, it will not do so to the extent that processing would override your interests, rights and freedoms to protect your personal data.
We may also use your personal data to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise or defend our legal rights, or when we are required to do so by applicable law.
In the situations set out below, we will only process your personal data when you have given us your specific consent and you have the right to withdraw your consent at any time (see Your rights below):
marketing and profiling purposes which are managed solely by Karpaz Gate Marina Limited as data controller for the KGM Group. Your decision to provide your data for such purposes is optional and will have no consequence on your ability to stay with us or benefit from the requested services;
all purposes concerning your booking, your stay and to provide you with the services you have requested, which are managed by Karpaz Gate Marina Limited as controllers. Your decision to provide personal data (including special category/sensitive personal data) to us is voluntary, however, if you do not provide such personal data you may no longer be able to benefit from our services.
We may process your personal data by both automated and manual means. We may use your personal data in other ways for which we provide specific notice at the time of collection.
We may share your personal data with third parties as described below:
third party service providers who have been appointed as data processors to perform functions and services on our behalf and who will be provided only with personal data necessary to perform the services on our behalf but are not authorized by us to use such data for any other purposes (e.g. providers of services in respect of web hosting, payment processing, information technology systems, customer relationship management, booking and reservations management, marketing, auditing, administration);
third party providers of components of any package holiday, excursion, transfer, concierge arranged activity/experience or other service we arrange for you;
to our advisors and insurers in the event of a claim, dispute or where otherwise necessary;
if we are required to do so by law or pursuant to legal process or to comply with any applicable rules or regulations, or in response to a request from a law enforcement authority or other government official; and
We will only send you marketing communications if you “opted in” to receiving such communications. You have the right to “opt out” of receiving marketing communications, whether by email or otherwise, at any time. You can do this by (i) clicking the unsubscribe link displayed in any of the marketing e-mails you receive, (ii) emailing email@example.com to indicate you no longer wish to receive marketing communications, or (iii) writing to us at the address set out in How to contact us below.
To help protect your privacy and maintain security, we may take steps to verify your identity before we can action your request.
We may transfer to, and store the data we collect about you in, countries other than the country in which you provided the data.
We maintain administrative, technical and physical safeguards designed to protect the personal data you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Service providers and contractors who might have access to your data in order to provide services on our behalf will be contractually obliged to keep such data in confidence, provide adequate data security measures, and may not use that data for any other purpose.
For your own protection, we encourage you not to include sensitive personal data, credit card or similar personal data in any e-mails you send us or our staff.
KGM only retains your personal data for as long as needed to fulfil the purposes for which it is collected, unless we are required or permitted by law to keep the personal data for longer.
Your personal data will be anonymised or deleted if your last interaction with KGM was over 7 years ago. “Interaction with KGM” includes for example visiting KGM or opening marketing communications from KGM.
Our website may provide links to other website for your convenience and information. These website operate independently from us. Linked website may have their own privacy policies, which we strongly suggest you review. To the extent that any linked website you visit are not owned or controlled by us, we are not responsible for the website’ content, any use of the website, or the privacy practices of the website.
The cookies we use on our website, where you have accepted their use, are:
Ensures that the user stays on the same server throughout their visit, ensuring consistent functionality throughout a visit. This cookie is destroyed at the end of the user’s visit
Ensures that the user’s session is maintained and works in conjunction with ARRPT to ensure consistent functionality throughout a visit. This cookie is destroyed at the end of the user’s visit
Allows use of flash to improve display of text (if the user’s browser supports it). This cookie is destroyed at the end of the user’s visit
These three cookies allow us to keep track of the users’ geographic location and language preferences in order to display them relevant targeted and localised content as applicable.
These cookies allow us to identify which of our marketing campaigns or internal promotions a user has been directed from/measure the effectiveness of campaigns/promotions.
These cookies allow us to identify the user and customise their experience. They also allow us to pre-populate fields in tables with your data, assisting with form entry.
In addition, the following are the third party cookies in use, where you have accepted their use (which are each subject to their own privacy and cookie policies):
Third Party Cookie
AppNexus collects anonymous data on users of the Site. The technologies utilized allow AppNexus to collect this data entirely anonymously and allow us to deliver interest-based advertising. AppNexus’ privacy statement can be found here http://www.appnexus.com//platform-policy
BidSwitch to collect this data entirely anonymously and allow us to deliver interest-based advertising. BidSwitch’s privacy statement can be found here http://www.iponweb.com/privacy-policy/
Microsoft collects anonymous information on users of the Site through to conversion to enable tracking of marketing.https://privacy.microsoft.com/en-gb/privacystatement/
Facebook Custom Audience
Allows KGM to create an audience using data held by Facebook to deliver interst-based advertising https://www.facebook.com/policy.php
Facebook Like Button
Google Dynamic Remarketing
Google +1 Button
InPowered is a machine learning, content distribution company. This technology facilitates the distribution of content via native advertising campaign planning, buying, management, delivery, optimization, measurement and analytics for advertisers and agencies and enables publishers to build, upload, host, serve, render and report on campaigns delivered to their web and mobile app properties https://inpwrd.com/privacy.pdf
LiveRamp allows KGM with CRM Retargeting through the use of anonymous cookies.
Qubit cookies collect non-personal information, for example to learn about the behaviour of visitors to our website and how they respond to our marketing communications. The more we learn, the better we are able to provide relevant and interesting content. Qubit provide a Global opt out function which you can use to switch off all Qubit cookies https://www.qubit.com/legal/product-privacy-policy/
Right Media collects anonymous information on users of the Site. The technologies utilized allow Right Media to collect this information entirely anonymously and allow us to deliver interest-based advertising. More information about Right Media can be found here http://info.yahoo.com/privacy/us/biz/rightmedia/details.html
Scorecard Research Tracking
ShareThis also makes use of Scorecard Research tracking which set the UID and UIDR cookies. Control your preferences or opt-out of Scorecard Research here.
Yahoo Advertising and Campaign Tags
by continuing to use the website you consent to their use; or
you must click an “I accept” box in order for cookies to be placed.
Data Protection Officer
Karpaz Gate Marina Limited
P.O. Box 12 – Yenierenkoy / Iskele
Kıbrıs – Mersin 10