Personal Data Protection Law

Custumer Privacy Notice

As Göçay-Onur Tur. İşl. Yat. Nak. Mad. ve Tic. A.Ş. / Hilton Dalaman Sapphire Resort & Spa – The Dalaman Golf Club (hereinafter referred to as the “COMPANY”), we attach the utmost importance to the security of your personal data. This Privacy Notice has been prepared, pursuant to Article 10 of the Law No. 6698 on the Protection of Personal Data (“KVKK”), to inform our guests who visit the Golf Club, establish membership, make a tee-time reservation, participate in a tournament, or otherwise benefit from our golf services.

1. IDENTITY OF THE DATA CONTROLLER

Trade Name: Göçay-Onur Tur. İşl. Yat. Nak. Mad. ve Tic. A.Ş. / The Dalaman Golf Club

Brand / Facility: Hilton Dalaman Sapphire Resort & Spa – The Dalaman Golf Club

Address: Sarigerme Mah. Dalaman / MUĞLA

Website: www.thedalamangolfclub.com

Registered Electronic Mail (KEP): [•••]

2. PERSONAL DATA PROCESSED, PURPOSES AND LEGAL GROUNDS

The table below shows which categories of your personal data are processed, for what purpose, and on which legal ground under the KVKK.

Data Category Data Processed Purpose of Processing Legal Basis (KVKK)
Identity and Contact Full name, date of birth, nationality, passport / national ID number, phone, email, postal address Membership setup, reservations, foreigner notification system (KBS) reporting, invoicing, communication Art. 5/2(c) (performance of a contract)

Art. 5/2(ç) (legal obligation)

Art. 5/2(e) (legitimate interest)
Membership and Golf History Membership type and dates, handicap, tee-time history, scorecards, tournament participation, rental equipment preferences, instructor/caddie assignment records (Golf Academy) Membership management, provision of golf services, tournament organisation, personalised service Art. 5/2(c) (performance of a contract)

Art. 5/2(f) (legitimate interest)
Financial Data Payment method (card type / last 4 digits), invoicing details, membership / green fee / equipment / pro-shop amounts. Payment processing, accounting, invoicing Art. 5/2(c) (performance of a contract)

Art. 5/2(ç) (legal obligation — Tax Procedure Law)
Health Data (Special Category) Declared physical limitations / disability status, golf cart usage requirements, emergency health notifications Safe provision of golf services, emergency response Art. 6/3(a) (explicit consent)

Art. 6/3(e) (public health / emergency response)
Visual and Audio Data Tournament / event photographs and videos, CCTV security camera footage, pro-shop entrance footage CCTV: security and facility protection. Tournament visuals: promotion / social media (with explicit consent) CCTV: Art. 5/2(f) (legitimate interest)

Visuals/promotion: Art. 5/1 (explicit consent)
Digital / Cookie Data Online reservation platform usage data, IP address, browser information, cookie records Online tee-time reservations, website optimisation, marketing analysis (with explicit consent) Art. 5/2(c) (performance of a contract)

Art. 5/1 (explicit consent — marketing cookies)
Guest Registration / Foreigner Notification (KBS) Passport details for foreign nationals, check-in/check-out dates; data reported to law enforcement authorities under Law No. 6458 Legal obligation: KBS notification Art. 5/2(ç) (legal obligation — Law No. 6458)

3. TRANSFER OF PERSONAL DATA

Your personal data may be transferred to the following recipient groups, for the purposes indicated, pursuant to Article 8 (domestic transfers) and Article 9 (international transfers) of the KVKK:

Recipient Group Purpose of Transfer Legal Basis
Hilton Hotels & Resorts (domestic / international headquarters) Guest profile, membership (Hilton Honors), group reservation management, central accounting Art. 8/2(a) (performance of a contract)

International: Art. 9 (explicit consent or adequate safeguards)
Golf Federation / Licensed Tournament Organisers/Agencies Handicap registration, tournament registration, national ranking system notifications Art. 5/2(c) (performance of a contract)

Art. 5/2(ç) (legal obligation)
Payment Institutions / Banks Green fee, membership, equipment rental, pro-shop payments Art. 5/2(c) (performance of a contract)
Suppliers and Service Providers Golf cart maintenance company, equipment supplier, IT/software providers, insurance companies, accounting/legal advisers Art. 5/2(c) and 5/2(f); as data processor, with the safeguards under KVKK Art. 12
Competent Public Authorities Tax authorities (Tax Procedure Law), law enforcement (KBS / Law No. 6458), health authorities (emergency), courts Art. 5/2(ç) (legal obligation)
Cloud / SaaS Infrastructure Providers (abroad) Reservation management system, email infrastructure, CRM, tournament management software Art. 9 — appropriate safeguards (standard contractual clauses or explicit consent)

4. METHODS OF COLLECTING PERSONAL DATA

Your personal data is collected through the following channels:

  • Membership application form (physical / digital)
  • Tee-time reservation form (Golf Club reception or online platform)
  • Check-in / guest registration form
  • Hilton Honors loyalty programme records
  • Tournament registration and participation forms
  • Pro-shop and golf cart rental transactions
  • Lesson / training appointment and caddie request forms
  • Telephone, email and website contact form
  • Security camera (CCTV) and digital access systems
  • Cookies and online reservation platform analytics tools

6. RIGHTS OF THE DATA SUBJECT UNDER ARTICLE 11 OF THE KVKK

Pursuant to Article 11 of the KVKK, you have the following rights:

  • a) To learn whether your personal data is being processed,
  • b) To request information if it has been processed,
  • c) To learn the purpose of processing and whether the data is used in accordance with that purpose,
  • ç) To know the third parties to whom your data is transferred, domestically or abroad,
  • d) To request correction of incomplete or inaccurate data and to request that this correction be notified to the parties to whom the data was transferred,
  • e) To request deletion or destruction of your data where the grounds for processing no longer exist, despite the data having been processed in accordance with the KVKK and other applicable laws, and to request that this be notified to third parties to whom the data was transferred,
  • f) To object to a result that arises to your detriment due to analysis carried out exclusively through automated systems,
  • g) To request compensation for damages arising from unlawful processing of your data.

7. APPLICATION PROCEDURE

To exercise the rights set out above, you may submit your request, together with documents verifying your identity, through the following channels:

Application ChannelDescription
Wet-Signed Written ApplicationYou may submit your application to the data controller’s address via notary public or in person.
Download as Word  – Download as PDF
Email (Securely Signed)You may send your application to kvkk@thedalamangolfclub.com using a secure electronic signature or registered electronic mail (KEP).
Download as Word  – Download as PDF
Online FormYou may submit your request by completing our Online Form.

Pursuant to Article 13/2 of the KVKK, your request will be concluded within thirty (30) days at the latest, depending on its nature. Responding to your application is free of charge; however, if the transaction requires an additional cost, the tariff determined by the Personal Data Protection Authority will apply.

8. UPDATES TO THIS PRIVACY NOTICE

This Privacy Notice may be updated in line with legal amendments or changes to our processing activities. The current version is available on our website (www.thedalamangolfclub.com).

Version Information

Version

Date

1.0

June 2026

TEE TIME REQUEST FORM

COURSE MAINTENANCE NOTICE

The Dalaman Golf Club will undergo its annual overseeding programme from 17 September to 2 October. During this period, the golf course will be closed to allow for essential maintenance works. We appreciate your patience as we prepare the course for an exceptional playing experience throughout the season.

Thank you for your patience and continued support.