Istanbul Royal Hotel

At Novalia Travel, S.L.U. (hereinafter, “NT”) we value your trust and privacy. For this reason, we will explain, below, simply and transparently, how exactly we use your data.

We encourage you to read carefully this privacy policy (hereinafter, the “Privacy Policy”) and if you have any questions or want more information in respect to this, you can write to us at info@novaliatravel .com and we will try to help you.

Who is the data controller?

The data controller is who decides the purpose for which your information is used, which in this case is NT, with Tax ID No. B-44921716 and domicile at Calle Paseo de la Habana 9-11, Madrid28036 . Telephone: +34 635 14 48 17 and email: info@novaliatravel.com

What data do we collect from you and for what purpose?

•            If you contact us via our online form, by email or any other means we provide, we will use your contact details to appropriately handle your request or query in accordance with its nature. This includes the possibility of contacting you and submitting this enquiry or request to the department that can provide you with a response.

The legal basis that allows us to carry out this processing of your data is your consent, which you give us when contacting us, and our legitimate interest in providing you the best possible service.

•           If you purchase an excursion for any of our destinations, we will use your data to comply with, develop, control and manage your purchase, with the aim of securing a proper delivery of our service. Among others, we may send you the booking confirmation and voucher, remind you about your booking, ask your opinion on the excursion or activity carried out in order to improve our service or inform you about any intended change.

The legal basis that allows us to carry out this processing is the execution of the contract.

If you wish to subscribe to our blog, we will ask you for your email address so that you can send new publications there.

The legal basis that allows us to carry out this processing of your data is your consent, which you give us when you provide us your email.

•            If you decide to abandon the purchase process, we will ask you for your email address in order to manage your next order.

The legal basis that allows us to carry out this processing of your data is your consent, which you give us when you provide us your email.

•            If you wish to download content such as catalogues, travel guides, etc., we will ask you for your full name and email address in order to provide you with the content you desire.

The legal basis that allows us to carry out this processing of your data is your consent, which you give us when you provide us your personal details.

•            If you use the Wi-Fi network, we will ask you for your full name and email address to manage the Wi-Fi service and to send you own or third-party commercial communications if you give us your consent. We will also ask you for this information to request comments, ask for ratings regarding the experience, improve our service and send you information about other activities and excursions you can enjoy at your destination.

The legitimate basis that allows us to carry out this processing of your data is, respectively, your consent and our legitimate interest in knowing the user’s experience and improving our service.

•           If you register to view your favourite products and your bookings, we will ask you for your full name and email address to manage your registration and enable you to view your favourite products and bookings.

The legal basis that allows us to carry out this processing of your data is your consent, which you give us when you complete the form and send it to us.

•           We may email you commercial communications about new services, attractions packages or other products and new developments that may be of interest to you. However, you may at any time object to the delivery of these commercial communications, in which case we will stop sending you them.

The legal basis that allows us to carry it out is our legitimate interest, in accordance with article 21.2 of the LSSI or, where applicable, your consent by you marking the corresponding box.

If you expressly request it, we can send you information about third-party products or services.

The legal basis that allows us to carry it out is your consent, which you give by marking the corresponding box.

•             When you browse our Website, we can take measurements and, where appropriate, analyse your browsing habits anonymously.

The legal basis that allows us to carry out this processing of your data is your consent, which you give when you accept the installation of our cookies and which you can revoke or configure at any time through our settings panel. You can find more information about the use of cookies in our Cookies Policy.

How long do we keep your data?

We will process your data for the time strictly necessary to fulfil the purpose they serve in each case. Once they are no longer necessary for the purpose that we process them, they will remain blocked for the sole purpose of attending to any responsibility or obligations that may arise from the processing thereof, after which they will be deleted.

Who do we share your data with?

Any sharing of data that we make will always be respecting your rights and in compliance with data protection regulations. In this sense, we will only share your data:

•            With service providers that help us carry out our activity, for example computer tools, technical support services, etc. Some of these providers may transfer data outside the European Economic Area (EEA). However, these communications are carried out with the necessary guarantees and have the level of data protection equivalent to the protection in Europe, as required by current regulations

•            In cases where it is necessary to comply with our legal obligations, the data may be communicated to public authorities and the State Security Forces and Bodies

•            To the Julià Group, because we jointly manage certain activities or matters

•            We will also send your data to third parties so they can send you commercial communications if you have provided us your consent

Registration and monitoring of corporate accounts on social networks

The data on the corporate profiles that NT has on the different social networks linked to this Website may be processed under other privacy policies. Specifically, the following corporate accounts are held by NT on social networks:

INSTAGRAM: https://help.instagram.comFACEBOOK: https://es-es.facebook.com/privacy/explanation

The profiles on social networks linked to this Website have been created for you to learn more about our activity and to provide different communication channels to people interested in our company and the services we offer.

What are your rights when you provide your personal data?

As the owner of your personal information, you have the right to:

•            Access the data that we process about you and detailed information about this processing

•            Request that your information be rectified if you consider it to be inaccurate

•            In some cases, request that your data be deleted, you can oppose our usage, and you can limit our processing thereof

•            Portability of your data, that is, to receive your data or to have it delivered to a third party in a format that allows them to process it

•            Withdraw your consent at any time in all processing that is subject to said legal basis

•            Contact the Spanish Data Protection Agency, by going to www.aepd.es, if you consider that we have not properly addressed your rights or you would like more information about them

If you have any questions regarding exercising your rights, before contacting the Control Authority, we remind you that, you are welcome to contact us directly by writing to info@novaliatravel.com and we will try to help you in the best possible way.

Changes to our Privacy Policy

NT may amend the information contained in this Privacy Policy when it considers this appropriate. Should it do so, we will notify you by various procedures through the Website (for example, through a banner or a pop-up) or your email. In any case, we suggest you to review this Privacy Policy from time to time in case changes are made to the Content.

Consequences of not providing your personal data

Our Website sometimes requires personal data. If you choose not to provide them, you will not be able to purchase the products and services/use their functionalities or they will be suspended or cancelled. When providing data is optional and you decide not to share them, the functions using this data, such as personalisation, will not work for you.

Last update: August 2021

1. General and registration details

Novalia TRAVEL, S.L. (hereinafter, “NT“)) is a company registered in the Commercial Registry of Madrid with Tax ID No. B-44921716 . Our contact details are as follows:

Address: Calle Paseo de la Habana 9-11, Madrid28036

Telephone: +34 635 14 48 17;

Email: info@novaliatravel.com

The Agency main mission is to provide a quality service with a clear desire to provide service to the citizens, thereby

contributing to quality urban mobility and establishing itself as a reference in passenger transport through the management of its lines and the optimisation of its resources. The use of the Website Novalia Travel implies the acceptance of each of the terms and conditions included in this Legal Notice; this notice should therefore be read carefully. There are also some services provided through this Website that are subject to their own general terms and conditions, which complement those contained in this Legal Notice and, they should therefore be read and accepted.

2. Purpose of the Conditions.

The purpose of these conditions of use (hereinafter, the “Conditions”) is to regulate the relationship between the website user (hereinafter, the “User”) and NT, offering the highest transparency and security guarantee, based on current regulations. Specifically, these Conditions regulate the access, browsing and use of the website (hereinafter,

the “Website”), notwithstanding NT reserving the right to amend them. Access to and use of the Website implies acceptance of its Conditions and of any amendment that may be carried out, as well as acceptance of its privacy policy and cookies policy.

These conditions are written in Spanish in their original version, so if the User accesses them in another language, where interpretation may be inconsistent, the Spanish version will prevail.

The validity of these Conditions coincides with the time of their communication until they are totally or partially amended, at which time the amended Conditions will become effective.

3. Free Access and Use of the Website

Access to the Website detailing the services provided by the NT is free for Users. Nevertheless, some of the services provided by NT through the Website are subject to payment of a fee, as determined in the corresponding General Terms Conditions and which must be accepted before proceeding with the purchasing process. Through the Website, NT enables Users to purchase tourist services in different cities and provided by third-party local operators. In no case will NT be responsible for any errors or omissions in the provided information, nor for the specific application or use that could be made thereof. NT reserves the right to amend at any time and without prior notice the content of the Website, this Legal Notice and any specific legal warning, as well as the General Terms and Conditions, the Privacy Policy or Cookies Policy that may be applicable to this Website.

4. Online contracting process

The User may access and contract the products and services offered by NT by accepting on the Website the corresponding General Terms and its Privacy Policy. Prior to initiating the contracting procedure, NT will make available to the User the General Terms and Conditions to which the contract will be subject, so they can be stored and reproduced. The General Terms and Conditions will be available in the languages that the Website is

translated.

Specifically, their acceptance and subsequent formalisation will be performed telematically on the Website. NT will keep a digital report on its acceptance and make it available for the User at any given time. In any event, after the acceptance, the User will receive an email acknowledging receipt of registration.

5. User Registration

In general, provision of the services does not require prior subscription or registration of the Users. Nevertheless, NT makes use of some of the services conditional upon prior completion of the corresponding form, which is available to those who wish to make use of the online ticket-sales service.

6. Authenticity of Information.

The User guarantees the authenticity of all the data supplied as a result of completing the necessary forms for providing the services. Similarly, the User will be responsible for keeping all the information supplied to NT permanently up to date and adapted at all times to the real situation of the User. In any event, the User will be solely

responsible for false or inaccurate statements made by them and for any damages that this might cause to NT or to third parties as a result of the information provided.

If the User detects an error after entering their data during registration, they may modify them on the platform or by contacting customer service at info@novaliatravel.com, as well as exercise the right of rectification provided for in our Privacy Policy if it were personal data.

7. Minors

In order to use the services, minors must first obtain permission from their parents, legal guardians or legal representatives, who will be considered liable for any act carried out by the minors in their charge. The required legal age for contracting services is 18, except for minors who have been empowered to this effect by their legal guardians.

Full responsibility for determining the specific content and services to which minors may have access lies with the legal guardians or legal representatives responsible for said minors. As internet allows access to content that may not be appropriate for minors, Users are notified of the existence of mechanisms, specifically computer programs for

filtering and blocking, which make it possible to limit the content available and, while these programs are not infallible, they are especially useful for controlling and restricting the material accessible by minors.

8. Obligation to use the Website and services

appropriately Users undertake to use the Website and services in accordance with the law and for the purpose for which they were created. To this end, Users will abstain from using any of the services for illicit ends or purposes, prohibited in this Legal Notice, or which harm the rights and interests of third parties, or in any way might damage, put out of action, overload, deteriorate or prevent the normal use of the services, computer or documents, files or any type of stored content in any computer (hacking) of NT of other Users or any User of the internet (hardware and software).

9. Obligation to use the Content appropriately

Users undertake to use the content made available to the Users on the Website, understood as, but not limited to the texts, photographs, graphics, images, icons, technology, software, links and other audiovisual or audio content, as well as the graphic design and source code (hereinafter, the “Content”), in accordance with the law, this Legal Notice,

the Specific and General Terms and Conditions of certain services and other notices, and, in particular, they undertake to abstain from:

– Reproducing, copying, distributing, making available or publicly communicating in any other way, transforming or modifying the Content, unless they have the authorisation of the owner of the corresponding rights or it is legal to do so

– Deleting, manipulating or altering in any other way any rights reserved and other identifying data

10. Placement of hyperlinks that allow access to the pages of the Website and the services

Users and, in general, those who intend to establish a hyperlink between their web page and the Website (hereinafter, the “Hyperlink”) must comply with the following terms:

– A frame will not be created over the pages of the Website

– No false, inaccurate or incorrect statements or indications will be made regarding NT, its directors, its employees, the web pages of the Website or the services provided

– The web page on which the Hyperlink is established will not contain information or content that is illicit, contrary to generally accepted moral standards and good manners or public order, nor will it contain content that is contrary to the rights of third parties.

The establishment of the Hyperlink does not, in any case, imply the existence of a relationship between NT and the owner of the web page on which the Hyperlink is established, nor the acceptance or approval by NT of its content or services

11. Intellectual Property

The entire Website, including texts, images, trademarks, graphics, software files, colour combinations, as well as the

Content’s structure, selection, arrangement and presentation are owned by NT, which holds all the rights over the Content. The information provided on the Website is the property of NT and of its authors and is considered protected work in accordance with the provisions of Royal Decree 1/1996 of 12 April, which approves the restated text of the law on intellectual property; it is also subject to the international treaties signed in this field.

This legal notice makes no transfer of rights in favour of the Users in relation to any of the elements that make up the

Website. Therefore, the reproduction, public communication, provision, distribution, commercialisation and transformation or any other activity over the Content of its Website is forbidden.

12. Data Protection

In accordance with the current regulations on Data Protection, all personal data submitted during the use of the Website will be treated in accordance with our Privacy Policy that all Users know and accept when they visit our Website.

13. Exclusion of guarantees and liability

13.1. Exclusion of guarantees and liability for the operation of the Website and its services

NT does not guarantee the availability or continuity of operation of the Website and services. Whenever reasonably possible, NT will provide notice of any interruptions to the operation of the Website and services.

NT disclaims, to the fullest extent allowed by the law, any liability for damages of any kind that may be due to the lack of availability or continuity of operation of the Website and services, or the failure of utility that Users might attribute to the Website and services and to the failures in access to the different web pages of the Website or those

from which the services are provided.

13.2. Exclusion of guarantees and liability for Content

• Quality. NT maintains all technical updates to prevent computer damage and complies with the technical measures of the LOPD in order to guarantee privacy; however, it does not guarantee the absence of viruses or other elements in the Content that may adversely affect your computer system (software and hardware) or the electronic documents and files stored in your computer system. NT disclaims any liability for damage of any kind that the presence of a virus or of other elements present in the Content might cause adverse effects to the computer system, electronic documents or files of the Users.

• Legality, Reliability and Utility. NT disclaims any liability for damages of any kind that may be due to the transmission,

dissemination, storage, making available, reception, obtaining or accessing of the Content by the Users, and, in particular, though not exclusively, for damages that may be due to the following:

• Failure to comply

with the law, as a result of transmission, dissemination, storage, making available, reception, obtaining or accessing of the Content Infringement of NT’s intellectual and industrial property rights, corporate secrets, contractual commitments of any kind, the right to honour, personal and family privacy and the image of people, personal data protection, property rights and rights of any other kind belonging to a third party as a result of transmission, dissemination, storage, making available, reception, obtaining or accessing of the Content Acts of unfair competition or unlawful advertising as a result of transmission, dissemination, storage, making available, reception, obtaining or

accessing of the Content Lack of truth, accuracy, exhaustiveness, pertinence and/or timeliness of the Content

Failure to comply, delay in complying, defective compliance or termination for any reason with or of the obligations contracted by third parties and contracts executed with third parties through or as a result of accessing the Content

Defects of any kind in the Content transmitted, disseminated, stored, made available or otherwise transmitted or made available, received, obtained, or those which have been accessed via the Website or services

13.3. Exclusion of guarantees and liability for services provided by third parties through the Website

•Quality. NT disclaims any liability for damage of any kind that might be due to viruses or the presence of other harmful elements in the services provided by third parties through the Website and that may cause

adverse effects in the computer system, electronic documents or files of the

Users.

13.4. Exclusion of guarantees and liability for information, content and services hosted outside the Website

The Website makes available to Users technical linking devices (such as links, banners, buttons, etc.), which allow Users to access the websites belonging to and/or managed by third parties (hereinafter, “Linked Sites”). The installation of these links on the Website has the sole purpose of facilitating access by the Users to the information, content and services available on said websites. NT does not offer or sell itself or through third

parties the information, content and services available on the Linked Sites, nor does it first control, approve, recommend or monitor them or make them its own property. NT does not guarantee or assume any liability for damage of any

kind that might be due to the following:

• the operation, availability, accessibility or continuity of the Linked Sites
• the maintenance of the information, content and services existing on the Linked Sites
• the provision or transmission of the information, content and services existing on the Linked Sites  
• the quality, lawfulness, reliability and utility of the information, content and services existing on the Linked Sites, provided by third parties through the Website

13.5. Exclusion of guarantees and liability for use of the Website, services and Content by the Users

NT disclaims any liability for damages of any kind that may be due to the use of the services and Content by the Users or which may be due to the lack of truthfulness, timeliness and/or authenticity of the information that the Users provide to other Users about themselves and, in particular though not exclusively, due to damages of any kind that might be due to identity theft of a third party carried out by a User in any kind of communication carried out through the Website.

14. Procedure in the event that illegal activities are carried out

In the event that any User or third party considers that events or circumstances exist that show the illicit nature of the use of any Content and/or the performance of any activity on the web pages included in or accessible through the Website should notify NT to the following email: info@novaliatravel.com .

15. Duration and termination

Provision of the Website service and the other services is, in principle, of indefinite duration. However, NT is authorised to terminate or suspend the provision of the Website service and/or any of the services at any time, without prejudice to the provisions of the corresponding General terms and conditions. Whenever reasonably possible, NT will provide notice of any termination or suspension of the provision of the Website service and other services.

16. Applicable law 

This Legal Notice is governed by Spanish law. The parties submit to the courts and tribunals of Madrid, unless any the law requires another jurisdiction. Nevertheless, both parties will do everything reasonably

necessary to try to resolve any conflicts in an amicable manner