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AZURINE YATÇILIK DANISMANLIK TURIZM VE TICARET ANONIM SIRKETI

and

YACHTCREWTURKEY.NET WEBSITE

PRIVACY POLCIY

This Agreement, which includes the rules that all the members have agreed, has been signed by and between “AZURINE YATÇILIK DANISMANLIK TURIZM VE TICARET ANONIM SIRKETI” (hereinafter referred to as “Yacht Crew Turkey ”in this Agreement) and yourself who have accessed to the website http://www.yachtcrewturkey.net that is owned by Yacht Crew Turkey, and it is deemed to have been signed without the requirement of an additional protocol between Yacht Crew Turkey and the visitors in the event that Yacht Crew Turkey is commenced to be used in any way.

Yacht Crew Turkey requires from the members their personal data at the time of and after the membership. Protection of personal data and sustaining privacy is our primary focus as the Yacht Crew Turkey team. For this reason, the information you have provided without be used outside the scope of the rules and purposes specified under the Terms of Use, and will not be shared with third parties.

Any information of any nature shared with Yacht Crew Turkey by the candidates who fill in the resume form on Yachtcrewturkey.net, will be shared with selective member employers in accordance with the services provided by the website. By sharing such information with Yacht Crew Turkey, the candidates hereby agree in advance with the sharing of the information as a matter of service type.

Yacht Crew Turkey shall not be held responsible for the breaching of the principles by the person and / or organization who becomes of a member of our Site but fails to abide by the privacy policy agreed upon between the parties.

In case of the following limited situations, Yacht Crew Turkey shall have the right to disclose users’ information to third parties outside the provisions of this “Privacy Policy”. Such situations being limited in number, shall be as follows;

Having to abide by the requirements stipulated by the legal rules that have been issued by the competent law authorities and that are in effects such as Law, Decree Law, Regulations, etc.;

Request made in relation to the users for the purpose of duly performance of a research or performance of an inquiry by a competent administrative and judicial authority;

Situations wherein giving information is required in order to protect the users’ rights or safety.

Provisions in relation to the Privacy Policy:

1. Certain sections can be accessed to by a user’s name and a password on Yacht Crew Turkey.net in order to protect the privacy of all the information pertaining to our individual and corporate members.

2. Member’s right to benefit from the Site only belong to that member, it cannot be transferred to others. The member is responsible for the privacy of his/her user’s name and password, and members are not allowed to let third parties or corporate use them. In case such misuse is identified by Yacht Crew Turkey, Yacht Crew Turkey shall have the right to terminate the related membership at any moment without having to give a reason.

3. Yacht Crew Turkey shall have no responsibility relating to the situations that may arise from the use of user’s name and password by third parties either with or without permission. Any legal and punitive responsibility that may arise shall lay with the Member. Breach of this Clause may cause the unilateral termination of the services provided to the Member as specified under Clause 2, without any notice. In case it is found out that the password is being used without permission, it shall be the Member’s responsibility to inform Yacht Crew Turkey.

4. Yacht Crew Turkey shall have no responsibility whatsoever regarding the negative outcome that may arise from the acts of individual and corporate members who fail to abide by and / or ignore the security-privacy policy which has been agreed upon as members of the Yacht Crew Turkey during the membership registration phase. In case of determination of such negative situation, it shall be the member’s responsibility to contact Yacht Crew Turkey immediately.

5. Yacht Crew Turkey hereby declares that it has taken all measures regarding electronic security expect for situations arising from force majeure and /or required by administrative-law enforcement units, and Yacht Crew Turkey further promises to its members that it will take all steps in order to prevent access to the data in case of electronic attacks by 3rd parties. In the event that a member’s data is stolen, deleted from the system or changes as a result of a cyber attack by 3rd parties, Yacht Crew Turkey undertakes to do its best to notify its Member as soon as possible.

6. Yacht Crew Turkey shall keep its members’ information within the framework of Law No: 6698 on Protection of Personal data. Member’s data will be used within the scope of the legislation for job and employee finding function only. Yacht Crew Turkey has the right to make changes to the privacy policy. All changes made will be notified to all the members.

7. Member may ask for information from Yacht Crew Turkey as to for what purpose his/her data is being used and which data is being used, and Yacht Crew Turkey undertakes to inform the member as soon as possible. Such information will be free of charge and if the required transaction entails a cost, Yacht Crew Turkey will ask the Member to pay the fee that is identified in the fee tariff determined by the Personal Data Protection Board after the transaction has been completed. Yacht Crew Turkey undertakes to carefully generate a solution as would be expected from Yacht Crew Turkey before the Member files a complaint t the Personal Data Protection Board regarding his/her questions, and Yacht Crew Turkey further promises to deliver such solution within its capacity pursuant to the Law on Protection of Personal Data.

8. Yacht Crew Turkey is responsible for keeping a Member’s identity, training and professional information for a period of 5 (five) years within the scope of the legislation and submit the same upon request of Turkish Employment Agency.

9. The intended use of Member’s information by Yacht Crew Turkey is as follows;

- Personal and Contact Information, Demographic Data: (Name, surname and contact information) are user for member registration, creating history, contract, business development, marketing and advertising activities, promotion and information.

- Social Network Information: is used in order to facilitate easier access to the site via Members’ current social network accounts and to provide better service by enhancing users experience together with the performance and development of operational activities such as business development, marketing, communication by means of data collected accordingly.

- Background information: is the information required for the site to deliver proper service.

10. Yacht Crew Turkey privacy policy is a document that contains the purpose of use of information that we have obtained in relation to our members and the method of use of the site.

11. Member hereby agrees that s/he will be deemed to have read and agreed to this Privacy Policy as a member to Yacht Crew Turkey, and the Privacy Policy take effect in relation to such member. In case of disputes arising from the performance of this Privacy Policy, the Central Courts and Bailiff Offices in İstanbul shall have jurisdiction for the settlement of such disputes.

12. Member hereby agrees that s/he shall ensure the preservation of personal data within the scope of Law no.6698 on Protection of Personal Data.

13. Member hereby agrees and undertakes that s/he has read, understood, agreed the entire clauses included within this accession Privacy Policy, and that s/he confirms the accuracy of the information s/he has given in relation to himself/herself.

14. We wish to thank you for your interest and trust in Yacht Crew Turkey’s privacy policy.

AZURINE YATÇILIK DANISMANLIK TURIZM VE TICARET ANONIM SIRKETI

POLICY ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

AND

DISCLOSURE FORM

TABLE OF CONTENTS

1. Purpose

2. Scope

3. Definitions And Abbreviations

4. Roles And Responsibilities

4.1 Data Controller

4.2 Data Controller Representative

4.3 Data Processor

4.4 Responsibility

5. Legal Obligations

5.1 Obligation To Inform

5.2 Obligation To Notify

5.3 Obligation To Ensure Data Safety

5.4 Obligation To Be Registered With The Data Controllers’ Registry

6. Classification Of Personal Data

6.1 Personal Data

6.2 Sensitive Personal Data

7.Policy On Processing Of Personal Data

7.1 Principles In Processing Of Personal Data

7.2 Yacht Crew Turkey’s Purposes For Processing Personal Data

7.3 Measures taken by Yacht Crew Turkey for the processing of Personal Data according to the Law

8. Policy On Transferring Of Personal Data

9. Personal Data Retaining Policy

10. Personal Data Security Policy

11. Rights Of Data Object

11.1 Right to access to personal data

11.2 The right to change or erase the personal data:

11.3 Keeping Personal Data Updated:

11.4 Application of the Data Subject and Assesment of Application:

12. Cookie Policy

13.Publishing And Storing Of Document

14. Updating Period

15. Effectiveness

1. PURPOSE

The Law on Protection of Personal Data was published in the Official Gazette dated 7th April 2016 and numbered 29677. The Law on Protection of Personal Data has been enacted in order to protect the fundamental rights and freedoms of natural persons whose personal data is processed, and their rights to privacy which is also being protected by the Constitution, and the purpose of this policy is to form management directives, procedural conditions and technical data to ensure that AZURINE YATÇILIK DANISMANLIK TURIZM VE TICARET ANONIM SIRKETI ( hereinafter referred to as “Yacht Crew Turkey”) processes and protects the personal information belonging to the data subject in accordance with the Law on Protection of Personal Data.

2. SCOPE

The employees who are affiliated to Yacht Crew Turkey, including the third parties who access to Yacht Crew Turkey network are all within the scope of this policy. The policy applies to all activities carried out and intended for the processing and protection of all the personal data either owned or managed by Yacht Crew Turkey.

This policy has been reviewed and prepared based on the Law on Protection of Personal Data and the regulation relating to the processing and protection of personal data.

Yacht Crew Turkey requires the contribution and support of all of its employees. Yacht Crew Turkey will provide sufficient training and supporting reference materials in order to ensure that the corporate assets are conveniently protected by all the employees within its organization.

This policy describes the basic controlling measures that are expected to be known and continuously practised by everyone within the body of Yacht Crew Turkey.

3. DEFINITIONS AND ABBREVIATIONS

In this section, private terms and phrases, concepts, abbreviations, etc. used in this policy are briefly defined.

3.1. Yacht Crew Turkey: AZURINE YATÇILIK DANISMANLIK TURIZM VE TICARET ANONIM SIRKETI

3.2. yachtcrewturkey.net : the web-site belonging to AZURINE YATÇILIK DANISMANLIK TURIZM VE TICARET ANONIM SIRKETI (hereinafter referred to as “Yacht Crew Turkey”)

3.3. Explicit Consent: is a limited consent given that is freely given and informed consent in relation to a specific matter for the purpose of data processing.

3.4. Anonymization: is rendering personal data which is impossible to link with an identified or identifiable natural person even through matching them with other data.

3.5. Employee: Yacht Crew Turkey’s personnel.

3.6. Service Provider: is the staff of a company (supplier, undertaker, client, etc.) from which Yacht Crew Turkey receives service and / or to which Yacht Crew Turkey provides service.

3.7. Personal Data Owner (Data Subject): is a natural person whose personal data has been processed.

3.8. Personal Data: is any information that relates to an identified or identifiable natural person.

3.9. Sensitive Personal Data: is any information that may cause the person being subject to unfair treatment or discrimination if obtained by others.

3.10. Processing of personal data: is any operation that is carried out on personal data such as collection, recording, storage, keeping, alteration, re-organization, disclosure, transferring, taking over, making retrievable, classification or preventing the use thereof, fully or partially through automatic means or through non-automatic means only for the process which must be a part of any data registry system.

3.11. Data Processor: is a natural or legal person processing the personal data on behalf of the Data Controller based on the authority given to the data processor by the Data Controller.

3.12. Data Controller: is a natural or legal person who determines the purposes for which and means by which personal data is processed and is responsible for establishing and managing the data registry system, and is obliged to get registered with the Data Controllers’ Registry.

3.13. Personal Data Protection Authority: Personal Data Protection Authority

3.14. Personal Data Protection Board: Personal Data Protection Board

3.15. Law on Protection of Personal Data: Law on Protection of Personal published in the Official Gazette dated 07 April 2016 under issue number:29677.

3.16. Policy: Yacht Crew Turkey’s Policy on Protection and Processing of Personal Data.

4. ROLE AND RESPONSIBILITIES

4.1 Data Controller

Processing of personal data is the series of operations that are carried out on personal data such as collection, recording, storage, retention, alteration, re-organization, disclosure, transferring, taking over, making retrievable, classification or preventing the use thereof, fully or partially through automatic means or through non-automatic means only for the process which must be a part of any data registry system.

Yacht Crew Turkey is responsible for the establishment and administration of a data recording system by determining the purpose and means of processing of the personal data that are registered in the data base, and Yacht Crew Turkey further declares that it will acquire the title of a registered data controller after getting registered as a data controller when the Data Controllers’ Registry is established.

4.2 Data Controller’s Representative

When the Data Controllers’ Registry is set up for all the affiliates within the body of Yacht Crew Turkey, Yacht Crew Turkey will appoint a data controller’s representative who is required for the registration with the Data Controllers’ Registry, and that personal will be an expert who shall then be responsible for the management and implementation of the activities of protection and processing of all the personal data, increasing of security measures and the performance of regular supervisions.

4.3 Data Processor

Data processor is a natural or legal person who processes personal data on behalf of and based on the authority granted by Yacht Crew Turkey ( for instance; undertakers, suppliers, etc.)

4.4 Responsibility

In case the personal data is processed by another natural or legal person on behalf of Yacht Crew Turkey, Yacht Crew Turkey as the Data Controller, and those who process the data shall be jointly responsible for taking the measures. Yacht Crew Turkey, as the Data Controller, shall periodically audit the compliance of the data processors with the privacy policy to ensure that the trust built between itself and the data subjects who share their personal data is also maintained in the same way as the service providers, suppliers and contractors.

5. LEGAL OBLIGATIONS

Pursuant to the Law on Protection of Personal Data, Yacht Crew Turkey has legal obligations within the scope of protection and processing of personal data. These obligations are listed as below:

5.1 Obligation to Inform

Yacht Crew Turkey is obliged to inform the data subject during the collection personal data, and inform the data subject regarding the following matters:

• the identity of the data controller and of his/her representative, if any,

• the purpose for which the personal data will be processed,

• the recipients to whom the data can be transferred, and the purpose of the transfer,

• the legal reasons of collection of personal data,

• the rights of the data subject

Within the scope of its obligation to inform, Yacht Crew Turkey will inform the data subjects regarding the processing of their personal data via different means. Furthermore, Yacht Crew Turkey gives importance to its policies that are open to public, being clear to the data subjects. Information is provided regarding the aforementioned matters under the terms of use and privacy agreements whict are on the Yacht Crew Turkey’s internet sites.d

The means and the method of informing the data subjects are specified in the domestic policies.

5.2 Obligation to Notify

As per Article 11 of the Law on Protection of Personal Data, the rights of the data subject from whom personal data has been obtained, pertaining to protection of personal data are specified under (Part 11). Pursuant to Article 13 of the Law on Protection of Personal Data, Yacht Crew Turkey will assess the request sent to its e-mail address info@yachtcrewturkey.net regarding the mentioned rights, and will be obliged to inform the data subject and such information shall be given within the period specified under the scope of the legal regulation.

Such requests should be made to Yacht Crew Turkey by the data subject either in writing or by any means to be determined by the Personal Data Protection Authority. Yacht Crew Turkey will try to provide further means to the data subject regarding the applications provided that Yacht Crew Turkey does not breach the decision of the Authority in this regard.

5.3 Obligation to Ensure Data Safety

Yacht Crew Turkey’s responsibilities as the Data Controller, arising from Article 12 of the Law on Protection of Personal Data, regarding the safety of data, are specified in Part 10 of this Policy.

5.4 Obligation to Register to the Data Controllers’ Registry

Yacht Crew Turkey is obliged to register with the Data Controllers’ Registry within the period that is determined and announced by the Personal Data Protection Authority pursuant to Article 16 of the Law on Proteciton of Personal Data.

According to Article 16/3 of the Law on Protection of Personal Data; in consideration of some objective criteria to be determined by the Personal Data Protection Authority such as the nature and number of processed personal data, legal requirements of data processing or transfer of the data to third parties, the Board may bring exemptions to some of the affiliates according to the exemption to be applied to the obligation to register with the registry.

6. CLASSIFICATION OF PERSONAL DATA

6.1 Personal Data

Law on Protection of Personal Data describes the personal data as any information relating to an identified or identifiable natural person (being able to reach that person when combined with another information). A person’s name, surname, date and place of birth, identity, social security number, telephone number, address, imahes, payment information, health information and similar information are within this description of personal data.

The subject matter of Protection of Personal Data is the natural persons whose data has been processed, and legal persons are left outside this description. For this reason, any information that includes information such as a legal person’s registration number, trading name and registry information that do not belong to a natural person are not protected as personal data under the Law on Protection of Personal Data.

6.2 Sensitive Personal Data

Sensitive personal data; is the information that may cause the data subject to suffer or be subject to discrimination when learned; such information is identified as follows under sub-paragraph 1, Article 6 of Law on Protection of Personal Data: People’s races, etnic origin, political view, philosophical beleif, religion, sect, or other beleifs, appearance, membership to association, fund or syndicate, health, sexual life, convictions, data relating to security measures and biomteric and genetic data. It is forbidden to process a person’s sensitive personal data without such person’s express consent other than cases where the law has explicitly given authority.

Within this scope; such personal data cannot be processed by Yacht Crew Turkey other than cases whereby such information is required to be processes by the Laws, or such information is processed upon Express consent of the data subject and in compliance with Article 6 of Law on Protection of Personal Data.

7. POLICY ON PROCESSING OF PERSONAL DATA

7.1 Principles in Processing of Personal Data

Pursuant to Article 4 of the Law on Protection of Personal Data, Yacht Crew Turkey shall be responsible for the processing of the data in accordance with the law and the principle of good faith, be accurate and up-to-date where necessary, intending certain, clear and legal purposes, keeping in connection with the goal, in a limited and measured way.

This means;

• Yacht Crew Turkey shall be obliged to act in accordance with the principles envisaged by the laws and other legal regulations during the processing of the personal data.

• Yacht Crew Turkey must be transparent and abide by the obligation to notify and inform during the processing of the personal data as a required of the principles of good faith.

• Yacht Crew Turkey must process the personal data based on legitimate and justifiable reasons, in other words personal data must be processed within limited purposes that are clearly stated in legal terms and in compliance with the law.

• Yacht Crew Turkey must process the personal data in connection with the activities it is carrying out.

• Yacht Crew Turkey must process the personal data in proportion to their purposes. The principle of proportionality should be taken into consideration in this regard, and the personal data should not be used outside their intended purposes. Besides, processing of personal data more than required to reach the goal or processing of personal data that is not needed must be avoided.

• Yacht Crew Turkey must retain the personal data for the period of time determined by the relevant regulation or the period deemed necessary for the purpose of the processing (See Part 9), and shall not keep the information even though such period has expired without making such data anonymous for any reason.

7.2 Yacht Crew Turkey’s Purposes for Processing Personal Data

Yacht Crew Turkey is processing personal data in accordance with Articles 5 and 6 of the Law on Protection of Personal Data for the following and similar purposes:

• Personal and communication data: Name-surname, telephone, email information are used for registration with the site and information purposes.

• Demoggraphic, Site and Application Navigation Data and Other Data: Data collected by identifying the users’ area of interests via, is used for the performance and development of operational activities such as job development, marketing, communication and also for providing better service by increasing the users’ experience.

• Social Network Information: the collected data is used for facilitating an easier access to the Site users’ existing social networks and for the performance and development of operational activities such as job development, marketing, communication and also for providing better service by increasing the users’ experience.

• Location Data: is only used when the user allows while the user is using the Yacht Crew Turkey.co mobile application. It involves data relating to the user’s sensitive or approximate locations. Location based promotion and information are provided that is specific to the user.

Other than the aforementioned data-based purposes, data is also collected in general for the following purposes.

To send feed to the Yacht Crew Turkey members,

• To send bulletion or notices to the Yacht Crew Turkey members via e-mail,

• To respond to the questions of Yacht Crew Turkey members or users and to provide an efficient user service,

• To give information to the Yacht Crew Turkey members about the new services,

• To do direct marketing by Yacht Crew Turkey or people with whom its is in cooperation,

• To contact the Yacht Crew Turkey members when necessary,

7.3 Meeting the Requirement for the processing of personal data according to the Law

Yacht Crew Turkey is obliged to take the following technical measures for the processing of the personal data according to the law,

To make intercorporate organization for the processing and storing of the personal data according to the law,

To establish the technical infrastructure to ensure the safety of the data base where the personal data will be stored,

To ensure the auditing of the technical infrastructure that has been established and its processes,

To identify the procedures relating to the reporting of the technical measures taken and the supervision period,

Yacht Crew Turkey takes the following organisational measures for the processing of the personal data according to law:

To inform and train the Yacht Crew Turkey employee for the protection and processing of the personal data according to the law,

To record the measures to be taken in case of processing of the personal data in breach of the law by the company’s employees in the agreements made with the company’s employees, documents or policies,

To supervise the personal data processing activities of the data processors and their partners with who Yacht Crew Turkey is working.

8. TRANSFERRING OF PERSONAL DATA

8.1 Domestic Tranferring of Personal Data:

Yacht Crew Turkey is obliged to act in accordance with the decisions and arrangements envisaged by the Law on Protection of Personal Data and made by the Personal Data Protection Authority regarding the transferring of personal data. Personal information and sensitive personal information pertaining to the data subjects can not be transferred by Yacht Crew Turkey to other natural or legal persons without the explicit consent of data subject. In so far as, personal data may be transferred to a competent administrative or judicial organization or body as envisaged under the regulation and being subject to certain limits without the explicit content of data subject where made obligatory by the Law on Protection of Personal Data and other Laws. Besides, in cases stipulated under Article 8 of the Law on Protection of Personal Data and as stipulated under the 2n paragraph of Article 5 (such as it being necessary for the formation or performance of an agreement or for the fulfilment of one of our legal obligations) or as stipulated under the 3^rd paragragh of Article 6 in respect of the sensitive personal data, such data may be transferred without the consent of data subject. Yacht Crew Turkey may transfer the personal data to third parties who are located in Turkey, in compliance with the conditions stipulated by the Law and by taking all the security measures.

8.2 International Transferring of Personal Data:

Yacht Crew Turkey is not only entitled to transfer personal data to third parties in Turkey, but it also may transfer the personal data that has been processed in Turkey to overseas or transfer the personal data to be processed and stored overseas. In exceptional cases wherein explicit consent is not required for the transfer of the personal data as specified under the Law on Protection of Personal Data, it is stipulated that the country to which the data will be transferred has adequate protection means in addition to the requirements for processing and transfer without consent. The Personal Data Protection Authority will establish whether or not adequate protection has been provided; in case there is not adequate protection, the data controllers both in Turkey and in the concerned foreign country must make a written commitment of an adequate protection and permission from the Personal Data Protection Authority is required.

8.3 Who/Which organization may do the transfer?

Authorized Institutions and Organizations:

Information requested by public legal entities within their related regulations are shared in accordance with Article 8.1.

For the purposes mentioned in Part 7.2, other people or organizations to which the personal data can be transferred as are follows; affiliate companies and/or direct/indirectdomestic/foreign affiliates that are jointly and successively responsible with Yacht Crew Turkey in the protection of any personal data, taking measures to avoid the prevention of unauthorized access and processing of personal data in breach of the law, and the domestic/foreignorganisations and other third parties from whom services are supplied within the scope of related agreements, with whom the Company is in cooperation, who are program partners for Yacht Crew Turkey to be able to perform its activities.

8.4 Measures taken by Yacht Crew Turkey for the transfer of the personal data in accordance with the Law:

Technical Measures:

Yacht Crew Turkey shall take the measures to avoid unauthorized access and use of the personal data that have been processed and transferred or obtained as a result of transfer, by the various departments within the body of Yacht Crew Turkey or the natural or legal persons who process the personal data on behalf of Yacht Crew Turkey based on the authority they have been given by Yacht Crew Turkey.

Organisational Measures:

Domestic policies have been established the means by which and the purposes for which and to whom the personal data should be given at the various departments within the body of Yacht Crew Turkey or the natural or legal persons who process the personal data on behalf of Yacht Crew Turkey based on the authority they have been given by Yacht Crew Turkey

9. PERSONAL DATA RETAINING POLICY

9.1 Retaining data for the period as envisaged by the related regulation or for the period required for the purpose of its processing

According to Article 7 of the Law on Protection of Personal Data and Article 138 of the Turkish Criminal Code, Yacht Crew Turkey retains the personal information it has processed on for a period that is envisaged under the concerned legislation or if there is no such period mentioned under the regulation, then for a period that is deemed necessary for the purpose of processing. Such retained data shall be erased after the purpose of retaining has come to an end, and such period has been determined as approximately 2 years although data which are envisaged with a longer period in terms of legislation shall continue to be stored in the system for for that period identified in the regulation.

For this reason, there might be different storing period for each personal data either as envisaged the related regulation or as stipulated according to its purpose of processing. For instance, as per Tax Procedure Law Artcile no:253, books and documents must be kept for a period of 5 years. Another example is that; as per Regulation on Commercial Communication and Commercial Electronic Messages, in case data subject’s approval is taken back relating to the use of personal data for marketing or promotion purposes, records of personal data must be kept for a period of 1 year as of such date. The content of commercial electronic message and any record pertaining to the post shall be stored for a period of 3 years in order to be submitted ot the concerned ministry when required.

On the other hand, a data might have been registered for more than one purposes and in such a case, the data is erased, destructed or kept after anonymized when all its processing purposes have disappeared.

9.2 Measures taken by Yacht Crew Turkey for the protection of Personal Data

Upon elimination of the purposes of processing of personal data or upon request of the data subject, the personal data that has been processed according to the Law on Protection of Personal Data and other related rules of law, must be erased, destructed or made anonymous by Yacht Crew Turkey so that it is impossible to use and retrieve such data. Procedures and principles in destruction or anonymization of the personal data according to the law must be in compliance with the principles and rules to be identified in the Regulation on Protection of Personal Data.

Technical Measures:

Systems and controlling echanisms are established in relation to the erasure, destruction and anonymization of the personal data by Yacht Crew Turkey.

Organisational Measures:

Yacht Crew Turkey ensures that the natural or legal persons who process data for and on behalf of Yacht Crew Turkey based on the authority vested in them by Yacht Crew Turkey, are informed and aware in relation to the keeping of the personal data according to the law, and also the personal data are retained, erased, destructed or anonymized by these people within the framework of the agreements made.

Yacht Crew Turkey is obliged to audit the personal dta retaining activities of the natural or legal persons who process the personal data on behalf of Yacht Crew Turkey based on the authority vested in them by Yacht Crew Turkey.

10. PERSONAL DATA SECURITY POLICY

10.1 Yacht Crew Turkey’s obligations regarding the data security

Pursuant to Article 12 of the Law on Protection of Personal Data, as the data controller, Yacht Crew Turkey’s obligations for the security of data are as follows:

•To take all the technical and organisational measures;

o to prevent the processing of personal data in breach of the law,

o to prevent access in breach of the law,

o to ensure the storing of personal data,

• To perform or to ensure the performance of the required supervision within the organization,

• To take the required measures to prevent the people or officers within its departments who process the personal data on Yacht Crew Turkey’s behalf from disclosing the personal data that has come to their knowledge during their employment, even though they leave their jobs and to prevent them from misusing such data,

• To notify the data subject and the Authority in case the processed personal data is captured by others illegally.

10.2 Measures taken by Yacht Crew Turkey for Data Safety

Yacht Crew Turkey takes the following measures for the fulfilment of its obligations regarding the safety of personal data and to ensure immediate action in case the data security is at risk:

10.2.1. Technical and organisational measures to prevent illegal access to the personal data.

Technical and organisational measures required to be taken are identified in the concerned parts relating to the processing, transferring and retaining of personal data. If third parties have accessed to the personal data illegally even though Yacht Crew Turkey is obliged to take such measures in full and prvent access in breach of law, Yacht Crew Turkey shall take all the technical and organisational measures according to the related regulation and decisions of the Authority to ensure that data subject is not harmed.

10.2.2. Measures taken for the protection of personal data and controlling of such measures.

It is periodically controlled that the data registration system that is being form and used within the body of the company has been formed in accordance with the Law on Protectionof Personal Data, and the outcome is reported to the person or organisation authorized in this regard.

Yacht Crew Turkey is obliged to inform and to create awareness in the natural or legal persons who process data on behalf of Yacht Crew Turkey based on the authority vested in them by Yacht Crew Turkey, in relation to the protection of the personal data according to the law, and also to identify the provisions for the protection of personal data by these people within the framework of the agreements made.

10.2.3. Measures to be taken in case of unauthorized disclosure of personal data.

Yacht Crew Turkey is obliged to take the required measures to avoid unauthorized disclosure of personal data and to establish a domestic policy in this matter. Besides, in such cases Yacht Crew Turkey acting in the capacity of data controller, shall be obliged to inform the people who disclose personal data without authorization and the Personal Data Protection Authority.

11. RIGHTS OF THE DATA SUBJECT

11.1 Right to access to personal data

Data subjects have the right to access to their personal data without being charged any fee. For this reason, Yacht Crew Turkey provides the data subject the following rights;

• To be informed whether their personal data has been processed or not;

• To request information if their personal data has been processed;

• To learn the purpose of processing of their personal data and whether the same is being used in complaince with their purpose;

•To learn such third persons in the home country or overseas to whom their personal data has been communicated.

11.2 The right to change or erase the personal data:

Data subjects have the right to change their personal data or to have them erased without being charged any fee. Within this scope, they have the right;

• to request amendment in case of incomplete or in accurate processing of their personal data;

• To request their personal data to be erased or destructed in case the reasons requirinng the processing of their personal data have disapperaed;

• To request that the third parties to whom their personal data are transmitted, are informed about such amendment, erasure or destruction procedures that are mentioned above;

• To object to the analysing of the processed data, exclusively by authomatic means, which leads to an unfavourable result for the data subject,

11.3 Keeping Personal Data Updated:

We have the obligation to ensure that your personal data is accurate and up-to-date where necessary, according to the Law on Protection of Personal Data. For this reason, please inform us in case of any change to ensure that your personal data is accurate and up-to-date. You may contact us on our customer service number 0252 3190092 (09.00 – 18.00) or e-mail address info@yachtcrewturkey.net

11.4 Application of the Data Subject and Assesment of Application:

Data Subject will be able to make a request to Yacht Crew Turkey in order to ensure access to the personal information processed by Yacht Crew Turkey as soon as possible and for the purpose of exercise of the rights mentioned above. Yacht Crew Turkey shall form the required application channels in order to meet such request for access. Applications are responded as soon as possible and in any case within the period envisaged under the Law on Protection of Personal Data.

Data Subject must apply to the representative who will be identified by Yacht Crew Turkey and announced in the Data Controllers’ Registry. Data Controller Representative shall meet the demands regarding the processing and protection of personal data according to their qualification as soon as possible and in any case within 30 days either free of charge or in return for the fee mentioned in the tariff in case the conditions in the tarif that will be published by the Board relating to the fees are met.

In order for such period to commence, the request made by the data subject must be in writing or must have been sent to the data representative by other means described bt the Personal Data Protection Board, and the documents that prove the identity of the data subject muct also be sent in full. All applications to be made until the Board stipulates a means for making applications, must be made in writing. During the application made by the data subject, it should be clearly stated by the data subject as to which of the rights the data subject is using along with the information and documents, if any, and such application must be sent to Yacht Crew Turkey’s address Fatih Sultan Mehmet Cad. CM İş Merkezi No:4 B-3 Konacık Bodrum MUĞLA – TÜRKİYE via registered mail.

Requests made by the data subject is either accepted by the data controller representative or rejected by giving explanation, and the answer is communicated in writing or via email. In case the application is accepted, Yacht Crew Turkey will do what is necessary and if the situation has arisen due to Yacht Crew Turkey’s fault, then the fee collected earlier is refunded. In some cases relating to the request made for the processing/ amendment/erasure of personal data, positive response cannot be given due to legal obligations or reasons specified under Articles 5 and 6 of the Law on Protection of Personal Data. In such cases, the reasons for such refusal will be explained in detail along with its legal grounds in the leter of rejection.

In the event that the application is rejected by Yacht Crew Turkey and the answer given is found insufficient or the answer is not given within its period, the data subject shall have the right to file a complaint to Personal Data Protection Authority within 30 days of such response and within 60 days of the application date in any case.

12. COOKIE POLICY

This cookie policy applies to the websites and mobile platforms operated by AZURINE YATÇILIK DANISMANLIK TURIZM VE TICARET ANONIM SIRKETI (hereinafter referred to as “Yacht Crew Turkey”) or on behalf of Yacht Crew Turkey, or the platforms that are accessed and used through third party programmes or websites.

Purpose Element: they are tiny data widgets placed in the devices (computer, telephone, tablet) with an aim to ensure that a cookie website operates properly, to improve ther user experience, to develop and optimize the site, to present mor eappropriate and interest based advertisements, to offer a website/ application and advertising portfolio that are customized and appealing to the visitors.

Cookie Types: Cookies may come in different types according to different classification forms. Cookies that are identified as session cookies are temporary cookies that are kept in your devices until you leave the site. Persistent cookies are the type of cookies that are stored on your device’s hard disk for a long time.

Compulsory cookies ensure that a website is working properly and users can visit the site and use its features. Compulsory cookies are anonymous.

Functional and analytical cookies include data to remind you of your preferences, ensure that the website is used efficiently, the website is optimized in order to fulfil the website users’ requests and they include information as to how the visitors use the site. As part of their features, such type of cookies may involve personal data such as user’s name, etc.

Commercial cookies, on the other hand, aim at enhancing your user experience by offering products/contents of similar nature that you have targetted through your area of interest and choices and also by offering a more improved, customized advertising policy.

The period during which the session, permanent, functional and commercial cookies are stored in the background is approximately 2 months and the person may do the required adjusments from the internet browser settings. This process of deletion from the settings may change based on the internet browser.

Third Party Cookies: Yacht Crew Turkey websites/ mobile applications/ mobile websites are operated by reliable and renowned third party advertisement providers. Third party providers place their own cookies in order to present adverts that are specifically for you. Cookies that are placed by the third party collect and process the visitors’ websites browsing information, and they anaylize how they use them.

Cookies Permissions: by using the Yacht Crew Turkey websites/mobile applications/mobile websites, you accept the use of cookies in compliance with the scope of “COOKIE POLICY”.

Information relating to the use of Cookies will be given by means of a pop-up window on the very first visit to the Yacht Crew Turkey websites/mobile applications/mobile websites. You will be deemed to have agreed to it when you close that window. As explained in the last paragraph of the aforementioned part under the heading” types of cookies”, it is possible to disable the cookie application.

Cookies Management: You may delete the cookie data that are stored until you disable the cookies. The place of such settings change according to the browser that you use. By using the “Help” function in your browser, you may find the settings.

In case you do not agree to certain cookies, please be informed that you may not be able to use some of the functions of our website or you may not be able to view the site properly.

13. PUBLISHING AND STORING OF DOCUMENTS

This data policy will be communicated to the users who have personal data, together with the obligation to inform within the scope of Law on Protection of Personal Data, and will be published on the sites that are affiliated to Yacht Crew Turkey.

14. UPDATING PERIOD

In case an amendment has been made pursuant to the company’s economic and commercial decision or Personal Data Protection Council’s resolution, such situation will be informed to our members whose data has been recorded, through the way they got registered.

15. EFFECTINESS

This data policy becomes effective on the date of its publication and shall remain to be in effect until it is removed from the internet site.

Azurine Yatçılık

Fatih Sultan Mehmet Cad. CM İş Merkezi No:4 B-3

Konacık Bodrum MUĞLA - TÜRKİYE

Tel: +90 252 319 00 92

info@azurineyachting.com