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GDPR

CHANNEL R DENIZCILIK YAT SATIŞ SERVIS DIŞ TICARET ITHALAT VE IHRACAT A.Ş.

CLARIFICATION TEXT FOR THE PROTECTION AND PROCESSING OF PERSONAL DATA

 

As CHANNEL R (shall also be referred to as “the company” hereinafter), we would like you to know that we have taken all the necessary legal, technical and administrative measures to protect your confidentiality within the scope of collecting, processing, transferring, deleting, destroying or anonymizing your personal data and/or personal data of particular nature in conformity with the Law No. 6698 on the Protection of Personal Data (“KVKK”) and the European Union General Data Protection Regulation (‘’GDPR’’, Reg. No: 2016/679), and would like to provide clarification on the purposes for which your personal data and/or personal data of particular nature will be processed, to whom and with what purpose they will be transferred, the method and legal causes of data processing as well as your rights.

1. Data Controller

As per the Law No. 6698 on the Protection of Personal Data and the European Union General Data Protection Regulation, your personal data and/or personal data of particular nature, the data of the company you own, your email and/or physical addresses, the new and second hand vessels you have leased or will lease, produced or have produced, have purchased or will purchase or sell, the ownership and license information of vessels, the information included in the sales and rent or after-sales processes, including but not limited to the above, various technical or qualified information regarding the marketing and sales or leasing of vessels and all kinds of visual and auditory data may be recorded, retained, processed, classified, updated, and in case allowed by the legislation and/or limited to their purpose of processing, may be disclosed/transferred to third parties by Channel R within its capacity as the “Data Controller” within the scope explained below and in conformity with law and rule of integrity.

2. Purpose of Processing Personal Data


At Channel R, personal data may be processed with the following purposes based on the relevant group of persons within the scope of the conditions of processing personal data provided in the Law No. 6698 and the European Union General Data Protection Regulation.


The personal data of customers or potential customers may be processed within the scope of the conditions of processing personal data provided in Articles 5 and 6 of the Law No. 6698 and in Articles 6 and 9 of the European Union General Data Protection Regulation to carry out the necessary work to accomplish the commercial activities performed by Channel R and to conduct business processes related to the same, to conduct the necessary works and business processes required for benefiting from products and services, to conduct the goods and services sale/lease and after-sales processes, to conduct the marketing analysis processes, to conduct communication activities, and to conduct product guarantee service processes.


The personal data of customers may be processed within the scope of the conditions of processing personal data provided in Articles 5 and 6 of the Law No. 6698 and in Articles 6 and 9 of the European Union General Data Protection Regulation to conduct goods and services purchase processes, to conduct after-sales/lease processes for goods and services, to conduct goods and services sales processes, to conduct company/product/service loyalty processes, to conduct activities in conformity with the legislation, to conduct finance and accounting operations, to follow requests and complaints, to conduct and audit business operations, to receive and evaluate recommendations regarding the improvement of business processes, to conduct operations for business process sustainability, to conduct customer relationships management processes, to conduct activities for customer satisfaction, to conduct marketing analysis studies, to conduct advertisement / campaign / promotion processes, to conduct communication activities, to conduct product and service development works, to conduct reward and raffle operations, to conduct product guarantee service processes.  


The personal data of customer candidates may be processed within the scope of the conditions of processing personal data provided in Articles 5 and 6 of the Law No. 6698 and in Articles 6 and 9 of the European Union General Data Protection Regulation to carry out the necessary work to accomplish the commercial activities performed by Channel R and to conduct business processes related to the same, to conduct the necessary works and business processes required for benefiting from products and services provided by Channel R, to plan and execute operations required for the offering and promotion of goods and services provided by the Company by customizing the same, to plan and execute customer relationships management processes.


The personal data of third parties may be processed within the scope of the conditions of processing personal data provided in Articles 5 and 6 of the Law No. 6698 and in Articles 6 and 9 of the European Union General Data Protection Regulation to carry out the necessary work to accomplish the commercial activities performed by Channel R and to conduct business processes related to the same, to conduct the necessary works and business processes required for benefiting from products and services provided by Channel R, to plan and execute operations required for the offering and promotion of goods and services provided by the company by customizing the same.


The personal data of visitors may be processed within the scope of the conditions of processing personal data provided in Articles 5 and 6 of the Law No. 6698 and in Articles 6 and 9 of the European Union General Data Protection Regulation to conduct marketing analysis studies, to conduct advertisement / campaign / promotion processes, to conduct communication activities, to conduct product and service development works, to fulfill legal obligations.

 

3. To Whom and for What Purpose Personal Data May Be Transferred

Your personal data and/or personal data of particular nature, processed or will be processed and specified in this clarification text, may be transferred within the framework of personal data processing conditions and purposes provided in Articles 8 and 9 of the Law No. 6698 and in Articles 45 and 49 of the European Union General Data Protection Regulation to the board of directors, business partners, project partners, authorities such as the Ministry of Commerce, Social Security Institution, Customs, Treasury, ministries, competent public authorities such as judicial authorities, and if the legislation allows so, to the collaborating consultants, organizations, parties, contractual organizations, payment systems organizations for the purposes of continuing services provided by Channel R, planning the policies and processes of our company, carrying out administrative processes for ensuring the continuity of services, ensuring the legal and commercial safety of the legal or real persons who are in a business relationship with our company, ensuring the physical security and control within and around the company facilities and buildings, conducting legal compliance processes, fulfilling the requirements of the fiscal and financial works, establishing and accomplishing commercial and business strategies.

4. Method and Legal Causes of Personal Data Collection

While it may change based on the nature of the relationship established with our company, your personal data and/or personal data of particular nature may be collected, processed and transferred with direct and indirect methods through any verbal, written or electronic media as per the purposes mentioned above and within the scope of the conditions and purposes of personal data processing specified in the relevant articles of the law to be able to provide the services of our company and perform the obligations of our company arising out of the company internal regulations (codes, directives, policies and procedures) and the contract and the law in full and complete.

5. Obligations of the Data Controller

5.1 Obligation of Clarification

The Data Controller and/or other persons authorized by the Data Controller are required to inform the persons, whose personal data are processed by other persons, regarding the collected personal data and/or personal data of particular nature within the following scope.

Such scope is namely:

​​The identity of the data controller, and if any, of their representative;

The purpose for which the personal data will be processed;

To whom and for what purpose personal data may be transferred;

Method and legal causes of personal data collection;

Other rights of the relevant persons as specified in the Law No. 6698 on the Protection of Personal Data and the European Union General Data Protection Regulation

The obligation of clarification may be carried out by the data controller and/or the person authorized by the data controller verbally, in writing or by utilizing physical or electronic media such as voice recordings and call centers.

5.2 Obligations regarding Data Security

As per Article 12 of the Law No. 6698 on the Protection of Personal Data and the relevant articles of the European Union General Data Protection Regulation, the obligations of Channel R regarding data security within its capacity as the data controller are as follows:

a) Preventing illegal processing of personal data;

a) Preventing illegal accessing of personal data;

c) Ensuring the retention of personal data, taking all kinds of technical and administrative measures necessary of ensuring the appropriate level of security;

d) Carrying out and having carried out the necessary audits for the purposes of implementing the provisions of this Law within their institution or organization;

e) Informing the relevant person and the Board as soon as possible if the processed personal data are acquired illegally by others.

Data controllers and persons authorized by them may not disclose the personal data they learned of in contradiction with the provisions of such Law and may not use the same except for their intended purpose. This obligation shall survive after they leave their duty.

6. Deletion, Destruction and Anonymization of Personal Data

If the reasons for processing the personal data are no longer existing even though the personal data were processed in conformity with the provisions of the Law No. 6698, other relevant laws and the European Union General Data Protection Regulation, such data shall be deleted, destroyed or anonymized by the data controller ex officio or upon the request of the relevant person.

7. Right of Data Owners as per GDPR

As the Data Owner, your Personal Data are also protected pursuant to GDPR. In cases where it falls within the jurisdiction of GDPR (citizens of the European Union or those who reside within the European Union Countries), the rights of the Data Owners shall be as follows:

7.1 Right to Access (Article 15 of GDPR):

The Data Owner shall have the right to apply to Channel R to confirm whether the personal data related to them were processed, and in case the personal data were processed, to learn the details provided under Article 15 of GDPR.

7.2 Right to Correction (Article 16 of GDPR): 

The Data Owner, at any time, shall have the right to apply to and have the Channel R correct their personal data, which have been changed and were retained at Channel R.

7.3 Right to Deletion (Article 17 of GDPR): 

The Data Owner shall have the right to request the deletion of their personal data retained at Channel R. In case the particulars provided under Article 17 of GDPR arise, your personal data shall be deleted by Channel R without delay.

7.4 Right to Limit Processing (Article 18 of GDPR):

If the Data Owners issue an objection regarding the currency of their Personal Data, the Data Owners shall have the right to limit the usage of their data as Data Owners until the accuracy of their Personal Data is confirmed by Channel R.

In case the Data Owner requests the deletion of their Personal Data due to processing operations being illegal, the Data Owner shall have the right to request the limitation of the use of their data until their request is realized.

In case the personal data are no longer needed to be processed by Channel R based on the intended processing purpose, the Data Owner shall have the right to request the limitation of the usage of their Personal Data.

If the Data Owners object to the processing operations as per Article 21/1 of GDPR, the Data Owners shall have the right to request the limitation of the usage of their data until it is determined that whether the legitimate reasons of Channel R in data processing outweighs the legitimate reasons of the Data Owner.

7.5 Right to Data Migration (Article 20 of GDPR):

The Data Owner shall have the right to request the migration of their Personal Data retained at Channel R to another controller at any time through an application. However, this right may be used when the data processing is based on consent or required by contract.

7.6 Right to Object (Article 21 of GDPR):

The Data Owner shall have the right to object to the processing of the Personal Data based on reasons related to their special conditions including the profiling within the scope of Paragraph (e) or (f) Article 6(1) of GDPR. Channel R may not process the Personal Data unless it provides a strong legitimate reason such as the establishment, exercise or protection of a right, whether it be legal or prevails over the interests, rights and liberties of the Data Owner.

In cases the Personal Data are directly processed for marketing purposes, the Data Owner shall always have the right to object the processing of personal data for such purposes, including profiling to the extent it is related to such direct marketing.

If the Data Owner objects to the processing of their Personal Data for direct marketing purposes, the Personal Data may no longer be processed for such purposes.

8. Personal Data Owner’s Rights within the Scope of the KVKK

As personal data owners, if you submit your requests to our company regarding your rights specified under the Law No. 6698 on the Protection of Personal Data with the procedures and methods specified below, our company will finalize your request within 30 (thirty) days the latest based on the nature of request.  However, if a transaction requires additional costs, a fee that is established by the Board may be collected. As per Article 11 of the Law No. 6698 on the Protection of Personal Data, the personal data owners shall have the rights to:

Learning whether their personal data were processed or not;

Requesting information about the processing of their personal data if they are processed;

Learning the purpose of processing the personal data and whether the same is used for their intended purpose;

Knowing the domestic or overseas third parties to whom the personal data were transferred;

Requesting the correction of personal data if they are processed inadequately or erroneously, and requesting the notification of such operations to the third parties to whom the personal data were transferred;

Requesting the deletion or destruction of the personal data in case the reasons for processing such personal data are no longer existing even though the personal data were processed in conformity with the provisions of this Law or other relevant laws, and requesting the notification of such operations to the third parties to whom the personal data were transferred;

Objecting when a negative consequence arises against the persons due to the analysis of their personal data with exclusively automated systems;

Requesting the compensation of damages if the person incurred damages due to the illegal processing of personal data.

9. Channel and Methods

The channels and methods you will use to submit your application within the scope of KVKK and GDPR on the Protection of Personal Data are explained below.

The following information must be stated in the applications made by the personal data owners:

a) Name, surname, and the application is in writing, signature;

b) Turkish ID number for the citizens of the Republic of Türkiye, and for foreigners, their nationality, passport number, and if any, identity number;

c) Address of residence or address of business for notifications;

d) Electronic mail address, telephone and fax numbers for notifications, if any;

e) Subject of request.

You may submit your request, which shall include your explanations regarding your rights that you have requested to exercise to exercise your abovementioned rights, personally in writing to the address of “Göcek Mahallesi, Uzman Kaptan Sokak No: 8 Fethiye, Muğla, Türkiye’’ together with your identification or by using our Organization’s electronic mail address of "info@channelr.com" or with other methods specified under KVKK and GDPR.

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