Privacy Policy and Data Notice on Processing of Personal Data
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.
This Privacy Policy applies to personal data that:
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.
The following sections of this Privacy Policy describe the types of personal data we collect, how and for what purposes we use that personal data, with whom we share it, and the choices and rights available to you regarding our use of your personal data. We also describe the measures we take to protect the security of the personal data we hold and how to contact us about our privacy practices, and to exercise your rights.
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
10. Cookies
11. Updates to our Privacy Policy
12. How to Contact Us
Karpaz Gate Marina Limited is KGM’s data controller and is registered in Turkish Republic of Norther Cyprus (TRNC).
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:
food allergies;
dietary requirements which may imply or suggest your religion, health or other sensitive personal data;
mobility requirements;
disabilities; and
medical conditions.
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;
domain name;
type of browser and operating system used (if provided by the browser);
URL of the referring page (if provided by the browser);
object requested;
completion status of the request;
geographic location; or
language preferences.
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 do not sell, otherwise disclose, or share data we collect and hold about you, except as described in this Privacy Policy.
We may share your personal data with third parties as described below:
other members of the KGM Group, or our affiliated companies, which may use this data to offer products and services to you consistent with the purposes identified in this Privacy Policy;
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 reserve the right to transfer personal data about you in the event that we sell or transfer all or a portion of our business or assets, in accordance with applicable law. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use data you have provided to us in a manner that is consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your data with any inquiries concerning the processing of that data.
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 info@karpazbay.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.
Those countries may not have the same data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy.
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.
A “cookie” is an element of data that a website can send to your browser which may then be stored on your system. We use cookies to gather data about the visitors to our website (as they enable us to improve our website and deliver a better and more personalized service). We do not associate the data in a website visitor’s cookie with any other data about that visitor.
The cookies we use on our website, where you have accepted their use, are:
Cookie Name
Function
ARPT
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
JSESSIONID
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
sifrFetch
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
user_countrycode
lounge_user_countrycode
user_lang_pref
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.
user_campaign
user_creative
user_placement
internal_user_campaign
internal_user_creative
internal_user_placement
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.
user_id
lounge_user_id
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
Function
Adroll
Adroll collects anonymous data on users of the Site. The technologies utilized allow Adroll to collect this data entirely anonymously and allow us to deliver interest-based advertising. Adroll’s privacy policy can be found here https://www.adroll.com/about/privacy
AppNexus
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
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/
Bing
Microsoft collects anonymous information on users of the Site through to conversion to enable tracking of marketing.https://privacy.microsoft.com/en-gb/privacystatement/
DoubleClick Advertising
Allows us to monitor (using non-personally identifiable data) the number and type of relevant searches made for it on Google. Privacy policy available at https://www.google.com/policies/technologies/ads/
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
Allows users to choose to show our website on their Facebook site. Privacy policy available at https://www.facebook.com/policy.php
Google Adwords
Google Adwords collects anonymous information on users of the Site through to conversion to enable tracking of marketing. The technologies utilized allow Adwords to collect this information entirely anonymously. Privacy policy can be found here : http://www.google.com/intl/en/policies/privacy/ You can opt-out of Google’s use of cookies by visiting the Ads Preferences Manager, or through the Network Advertising Initiative opt-out page.
Google Analytics
Monitors usage of site (using non-personally identifiable data). Privacy policy available at www.google.com/intl/en/analytics/privacyoverview.html You can opt-out of Google’s use of cookies by visiting the Ads Preferences Manager, or through the Network Advertising Initiative opt-out page.
Google Dynamic Remarketing
The KGM Group are using ‘Remarketing’ to advertise online. This means that third-party vendors, including Google, will show ads on sites across the Internet. Google will use cookies to serve ads based on past visits to this website. Privacy policy can be found here : http://www.google.com/intl/en/policies/privacy/
You can opt-out of Google’s use of cookies by visiting the Ads Preferences Manager, or through the Network Advertising Initiative opt-out page.
Google +1 Button
Allows users to choose to show our website on their Google + account. Privacy policy available at www.google.com/intl/en/+/policy/+1button.html
HotJar
Hotjar uses cookies to process information including standard internet log information and details of the visitor’s behavioral patterns upon visiting our site. This is done to provide our users with a better experience, and to facilitate the use of certain functions. https://www.hotjar.com/legal/policies/privacy
InPowered
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
LiveRamp allows KGM with CRM Retargeting through the use of anonymous cookies.
http://liveramp.com/data-privacy-policy/
Maxymiser
Maxymiser cookies allow KGM to discover how our website are working and optimise their customer experience using analytical cookies. Privacy policy available at https://www.maxymiser.com/cookie-policy
MediaPlex
Enables the direct measurement of traffic and audience characteristics. Privacy policy available at mediaplex.com/legal/mojo-privacy-statement
Qubit
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/
OwnerIQ
OwnerIQ collects anonymous information on users of the Site. The technologies utilized allow OwnerIQ to collect this information entirely anonymously and we will never be able to identify you individually based on this information that is collected. Privacy policy can be found here http://owneriq.com/privacy-policy
OpenX
OpenX collects anonymous information on users of the Site. The technologies utilized allow OpenX to collect this information entirely anonymously and allow KGM to deliver interest-based advertising. OpenX ‘s privacy policy can be found here http://openx.com/legal/ad-exchange-privacy-principles/
Quantcast
Enables the direct-measurement of traffic and audience characteristics, using non-personally identifiable data. Privacy policy available at http://www.quantcast.com/privacy
Rocket Fuel
Enables the direct measurement of traffic and audience characteristics. Privacy policy available at http://rocketfuel.com/privacy-policy
Right Media
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.
ShareThis
We use ShareThis to provide buttons on all pages to help you share our content. ShareThis also makes use of Scorecard Research tracking which set the UID and UIDR cookies. For more information on how to opt-out of these cookies view the ShareThis privacy policy.
Sizmek
Sizmek collects anonymous information on users of the Site. The technologies utilized allow Sizmek to collect this information entirely anonymously and allow us to deliver interest-based advertising. The Sizmek privacy policy can be found here
Sojern
Sojern cookies collect non-personal data about behavior and travel intent. Privacy policy can be found at http://www.sojern.com/privacy/
Twitter Advertising
Allows interest-based advertising. Privacy policy https://twitter.com/privacy
Yahoo Advertising and Campaign Tags
Allows us to monitor (using non-personally identifiable data) the number and type of relevant searches made for it on Yahoo. Privacy policy available at info.yahoo.com/privacy/us/yahoo/details.html
Yandex
Allows users to search for our website in the Russian language. Privacy policy available at company.yandex.ru/legal/en/confidential/
We do not control the use of such third party technology and we are not responsible for any actions or policies of such third parties. When you access our website you will receive a clear notice advising you that the website you are visiting intends to use cookies and that:
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.
Unless you have adjusted your browser setting so that it will refuse cookies from our website, our system will issue cookies. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting www.allaboutcookies.org. Please note, however, that without cookies you may not be able to take full advantage of all our website features.
This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our processing of your personal data and privacy practices. We will post a prominent notice on KGM’s website to notify you of any significant changes to our Privacy Policy and indicate at the top of the Privacy Policy when it was most recently updated.
If you have any questions or comments about this Privacy Policy, the use of cookies, if you would like us to update personal data we have about you or your preferences, or to exercise Your rights (as detailed above), please email our data protection office at info@karpazbay.com or write to us at:
Data Protection Officer
Karpaz Gate Marina LimitedÂ
P.O. Box 12 – Yenierenkoy / Iskele
Kıbrıs – Mersin 10
Turkey
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Anna Tyc offers intensive vinyasa practice with chanting mantra pranayama meditation and hands on assist.
She is 800h. certified Ashtanga Vinyasa teacher with 300h. of mentorships, which she completed in India and Germany.
For Anna yoga is a spiritual and energetical practice, a journey to selfdiscovery and she aims to share her passion to yoga life style, and make yoga accessible to everyone.
Anna is grateful to all incredible teachers who inspired her path: BNS Iyanger
Mandala Mysore, Gregor Maehle, Monica Gauci ,Richard Freeman, Netta Barnea.
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Anna Tyc was born in Warsaw Poland and raised in Berlin Germany, where
she started her journey as a yoga student and teacher.
She is co-founder of High On Yoga Berlin studio, where she is still sharing her practice with Berlin community.
In 2018 Anna relocated to Tel Aviv, Israel where she continues her path as a yoga teacher and student.
Practicing the work of mat is a challenging combination between the movement of Dance, the depth and power of Yoga and the wisdom of the Pilates.
After many years of teaching a diverse range of methods and exploring the world of body and movement, Reut Brandes is revealing a new and expanded repertoire of the body movement.
The Art of mat © introduces us to the tools that will help us understand the complex meaning of the movement, focusing on specific details which allow us to control and improve our abilities.
The goal is to internalize and combine physical sensations that lead to implement the body and soul wisdom.
Reut Brandes is a mat and equipment pilates and Yoga instructor. Graduated with a bachelor’s degree (Hons BA) in dance and movement from the London Contemporary Dance school. Studied and trained with first class teachers in Europe: Alan Herdman studio, Pilates Off the Square, Belsize Studio.
She has extensive experience working with different populations and in recent years has been guiding rehabilitation and movement teams in New York.
