SUNSEEKER TURKEY YATÇILIK HİZMETLERİ LİMİTED ŞİRKETİ 

PERSONAL DATA PROCESSING

UNDER THE PROTECTION OF PERSONAL DATA LAW NO.6698

Sunseeker Turkey Yachting Services Limited Company (“Company‘‘), takes all kinds of technical and legal measures in accordance with Personal Data Protection Law No.6698 (‘‘KVKK‘‘) in the processing of your personal data due to the activities it carries out. Relevant persons can access detailed information on the processing of their personal data, their transfer to third parties, the legal reasons for collecting personal data and their rights under the KVKK in the following text.

A. Processed Personal Data, Data Processing Purpose, Method of Collection and Legal Reason for Processing

The legal reasons our company is based on during data processing are as follows:

• Existence of explicit consent (‘‘a.5 / 1, a.6’‘).
• It is clearly stipulated in the laws (‘‘a.5 / 2-a’‘).
• In the event that the person who cannot explain his/her consent due to the actual impossibility, or it is mandatory for the protection of the life or bodily integrity of the person whose consent is not legally valid, or of another person. (“a.5/2-b”)
• Provided that it is directly related to drawing up or performing a contract, it is required to process personal data of the parties of the contract. (“a.5/2-c”)
• It is mandatory for the data controller to fulfill its legal obligation (‘‘a.5 / 2-ç’‘).
• It is made public by the person concerned (‘‘a.5 / 2-d’‘).
• Data processing is mandatory for the establishment, use or protection of a right (‘‘a.5 / 2-e’‘).
• If data processing is required for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the relevant person are not damaged. (“a.5/2-f”).

Data Processing Purpose	The Personal Data Processed	Data Processing Conditions	Data collection methods
Management of request and complaint processes	Name, surname, e-mail, phone number, title, signature, request / complaint detail	a.5 / 2-e, a.5 / 2-f.	By electronic means (Partially automated means)
Execution of goods / service procurement and contract processes	Name, surname, TR ID, signature circular, e-mail, telephone, tax office, bank account number, signature, address, reference information	a.5 / 2-c, a.5 / 2-d, a.5 / 2-e.	By physical means, by e-mail and telephone (Partially automatic and non-automatic ways)
Execution of sales and contract processes	Name, surname, TR ID, signature circular, e-mail, telephone, tax office, tax office, bank account number, signature, address	a.5 / 2-c, a.5 / 2-d, a.5 / 2-e.	By physical means, by e-mail and telephone (Partially automatic and non-automatic ways)
Execution of billing processes	Name, surname, VKN, TR ID, e-mail, phone, address.	a.5 / 2-a, a.5 / 2-c, a.5 / 2-ç, a.5 / 2-e.	Physical or digital means (non-automatic or partially automated means)
Preparation of audit documents	Name, surname, TR ID, signature, e-signature	a.5 / 2-c, a.5 / 2-f	Through the relevant document (non-automatic means)
Preparation of the minutes of the general assembly meeting and power of attorney and recording the meeting	Name surname, T.R. ID number, signature, title, visual and audio videos	a.5 / 2-ç, a.5 / 2-f	By physical means, via e-mail and camera (Partially automatic and non-automatic ways)
Follow-up of litigation, mediation and enforcement processes	Personal data subject to the file and / or contained in the file	a.5 / 1,  a.6 / 1,  a.5 / 2-a, a.5 / 2-d, a.5 / 2-e, a.5 / 2-f.	Physical and e-mail (Partially automatic and non-automatic means)
Delivery of incoming and outgoing call records and mails to relevant places	Name, surname, phone, e-mail, institution, title, address.	a.5 / 2-f.	By physical means, by fax and e-mail (Non-automatic or partially automated means)
Listing phone numbers in order to maintain communication	Name, surname, title, phone.		By e-mail, phone, physical means (Partially automated means)
Correspondence with public institutions and organizations	Name, surname, address, Turkish ID number, ID serial number, date of birth, mother and father name, title, photo, video, phone, e-mail, signature	a.5 / 2-a, a.5 / 2-c, a.5 / 2-ç	By physical means or by e-mail (Non-automatic or partially automated means)

B. Transfer of Personal Data

Your personal data, which is stated to be processed in the 1st title, in line with the data processing purposes under the same heading, in case of necessity and limited to the necessary in the realization of our company activities and business processes are transferred to;

• In accordance with the provisions of the relevant legislation, audit firms, financial advisors, relevant public institutions and organizations ( Execution of activities in accordance with the legislation, Fulfillment of our legal obligations, Management of contract processes),
• Banks and financial institutions, ( Execution of contract processes, execution of finance and accounting affairs, follow-up and execution of legal affairs),
• The suppliers and business partners involved in the business processes for the realization of the activities (Ensuring / auditing business continuity, Execution of contract processes, Follow-up of requests and complaints, HFollowing and executing legal affairs)
• The relevant supplier company from which our company provides services in business processes, to our business partner (Ensuring / auditing business continuity, execution of contract processes, follow-up of requests and complaints, follow-up and execution of legal affairs)
• legally authorized public institutions and organizations in line with the demands of the relevant public institutions and organizations and limited to the purposes of the request, (Carrying out activities in accordance with the legislation, following and carrying out legal affairs, fulfilling our legal obligations in accordance with legal / administrative regulations),

C. Rights of the Related Person

Everyone has the following rights in accordance with Article 11 of the KVKK;

1. To become aware of whether the personal data has been processed or not,

2. To request information if your personal data has been processed,

3. To learn the purpose for processing personal data and whether they are used in line with their purpose,

4. To learn about the third parties to whom personal data are transferred domestically or abroad,

5. To request correction of personal data that have been incompletely or inaccurately processed and to request that the third parties to whom the data were transferred be notified of the action taken in this regard,

6. To request deletion or disposal of the personal data in the event that, even though the personal data have been processed in compliance with the LPPD and other relevant laws, the causes for processing disappear, and, in this extent, to request notification of such deletion or disposal to the third persons to whom the personal data have been transferred,

7. To object to any adverse consequences arising as a result of processed data being analyzed solely by automatic systems,

8. To claim compensation for any harm caused by the unlawful processing of personal data.

Everyone can submit their requests regarding these rights to our Company in accordance with the Communiqué on Application Procedures and Principles to the Data Controller. Claims will be evaluated and decided free of charge as soon as possible and ultimately within thirty (30) days at the latest. If the evaluation and decision-making process requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board will be taken as basis.