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Gizlilik ve K.V.K.K. Politikası

*PRIVACY AND PERSONAL DATA PROTECTION POLICY*

As begumyachting.com, we take utmost care to ensure the security of your personal data. Your personal data is processed and stored in compliance with the Law No. 6698 on the Protection of Personal Data ("KVKK").

1. *How Your Personal Data Can Be Processed*

In accordance with the KVKK No. 6698, your personal data shared with begumyachting.com can be processed by us either wholly or partially, automatically or non-automatically, by being a part of any data recording system, through the acquisition, recording, storage, alteration, reorganization, and all kinds of processing. Any operation performed on data as per the KVKK is considered "processing of personal data."

2. *Purposes and Legal Grounds for Processing Your Personal Data*

The personal data you share will be processed in compliance with the KVKK and related secondary regulations for the following purposes:

- To fulfill the requirements of the services we provide to our customers, in accordance with the necessities of the contract and technology;
- To provide information to prosecutors, courts, and relevant public officials upon request and as required by legislation concerning public safety and legal disputes;
- To offer our members a wide range of opportunities or to share such opportunities with individuals or institutions that can offer these opportunities within a legal framework;
- To analyze advertising preferences.

3. *Information About Third Parties or Organizations to Which Your Personal Data May Be Transferred*

For the above-mentioned purposes, the personal data you share with begumyachting.com may be transferred to our main shareholders, shareholders, advertisers, direct or indirect domestic/foreign affiliates; to the member firms using the begumyachting.com infrastructure, and to individuals and institutions involved in the services provided, and to partner organizations, service providers, program partner organizations, domestic/foreign organizations, and other third parties and organizations with whom we collaborate to carry out our activities and/or from whom we receive services as data processors.

Our regulations regarding cookies used for advertising purposes are part of the "begumyachting.com Cookie Policy," which is currently part of this "Privacy and Personal Data Protection Policy." For information about our Cookie Policy, please click here. (You can access the necessary cookie policy example via the link at the bottom of the document.)

4. *How Your Personal Data Is Collected*

Your personal data can be collected through the following methods:

- From forms on the begumyachting.com website and mobile applications with information such as name, surname, address, phone number, work or private email address; from preferences on pages accessed with a username and password, from IP records of transactions, cookie data collected by the browser, navigation times and details, and location data;
- From individuals who share their personal data for purposes such as establishing a commercial relationship with begumyachting.com, applying for a job, making offers, etc., received in physical or virtual, face-to-face or remote, verbal, written, or electronic environments;
- From data obtained indirectly from different channels, such as websites, blogs, contests, surveys, games, campaigns, (micro) websites used for similar purposes, and social media, e-newsletter reading or clicking movements, data provided by publicly available databases, social media platforms (Facebook, Twitter, Google, Instagram, Snapchat, etc.) from open profiles and data on social sharing sites.

5. *Personal Data Obtained Before the KVKK Came Into Effect*

Since begumyachting.com did not start its publication life before the effective date of the KVKK, April 7, 2016, there is no personal data stored before this date. (If your website collected data before this date, it must be stated how the data was processed and stored.)

6. *Transfer of Your Personal Data*

Your personal data, collected by any of the above-mentioned methods, can be transferred abroad for processing and storage purposes to service intermediaries (in countries accredited by the Personal Data Protection Board where sufficient protection for personal data exists), as per the KVKK and in compliance with the purposes of the contract.

Your personal data may be transferred to:

- Our business partners with whom we cooperate and/or receive services for the presentation and promotion of products and services,
- Authorized authorities that will determine your location in case of an emergency call,
- Regulatory and supervisory institutions, official institutions such as courts and enforcement offices, and other public institutions or organizations authorized to request personal data,
- Legal entities with which begumyachting.com has commercial relations and who have your phone number.

7. *Storage and Protection of Personal Data*

begumyachting.com is obligated to prevent unlawful processing of personal data, prevent unauthorized access, and ensure its preservation by taking necessary software measures like hashing, encryption, transaction logging, access management, and physical security measures to protect the systems and databases where your personal data is stored, as required by Article 12 of the KVKK. If it is learned that personal data has been obtained by others through unlawful means, the situation will be reported immediately, in accordance with the legal regulations, and in writing to the Personal Data Protection Board.

8. *Keeping Personal Data Accurate and Up to Date*

According to Article 4 of the KVKK, begumyachting.com has an obligation to keep your personal data accurate and up to date. Therefore, our members are required to share accurate and up-to-date data with begumyachting.com or update them via the website/mobile application so that begumyachting.com can fulfill its obligations arising from the current legislation.

9. *Rights of the Personal Data Owner Under KVKK*

Article 11 of the KVKK, which came into effect on October 7, 2016, grants the following rights to Personal Data Owners regarding their personal data:

- Learn whether their personal data is processed or not,
- Request information if their personal data is processed,
- Learn the purpose of the processing of their personal data and whether they are used in accordance with their purpose,
- Know the third parties in the country or abroad to whom personal data have been transferred,
- Request the correction of the personal data if it is incomplete or incorrectly processed,
- Request the deletion or destruction of the personal data within the framework of the conditions set forth under Article 7 of the KVKK,
- Request notification of the processes to third parties to whom personal data have been transferred,
- Object to the occurrence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,
- Claim compensation for the damage arising from the unlawful processing of the personal data.

10. *Contact and Application Method*

A Data Controller Representative appointed by begumyachting.com will be announced in the Data Controllers Registry and on the website when the legal infrastructure is provided. Personal Data Owners can direct their questions, opinions, or requests to info@begumyachting.com.

begumyachting.com can respond to the requests within 30 days, either positively or negatively, by providing reasons, in written or digital form. It is essential that necessary procedures related to requests are free of charge. However, begumyachting.com reserves the right to demand a fee if the procedures incur a cost. These fees are determined based on the tariff set by the Personal Data Protection Board in accordance with Article 13 of the Personal Data Protection Law.

By sharing your personal data on our website, applications, and other channels, you declare that you accept our Personal Data Policy and the conditions stated in the policy regarding processing, methods of processing, transfer, sale, and other related matters; that the data shared with a social media application called begumyachting.com can be used on the website, applications, and social media channels, for notifications and suggestions, and can be shared with third parties for commercial purposes for the benefit of the members, and that you agree to this with explicit consent, which is defined as consent given with free will based on being informed about a specific topic, that has great importance under the KVKK.