Marinsa Shipping LTD. “KVKK” – “GDPR” Policy

As Marinsa Shipping Inc. we respect the personal data you have shared with us, and we care about the protection of fundamental rights and freedoms, particularly privacy. We would like to inform you in detail about the protection of your personal data under Law No. 6698 on the Protection of Personal Data (”KVKK”), the manner in which your personal data is collected, the purposes of processing, the legal bases, and our mutual rights and obligations.

Your personal data may be obtained, recorded, stored, disclosed, transferred to third persons or abroad to the extent permitted by legislation, or processed in other ways by Marinsa Denizcilik A.Ş. ("Marinsa") as Data Supervisor, in accordance with the provisions of the KVKK and in the framework described below.

Collection of Your Personal Data

Your personal data may be collected by Marinsa verbally, in writing or electronically through automatic or non-automatic means, in the conduct of human resources procedures, through call centers, during recruitment processes, under employee-employer relations, and during trainings, seminars or organizations held by Marinsa. For physical security purposes our company carries out surveillance activities at our workplaces and offices through security cameras, and records the entrances and exits of our visitors.

The Purpose For Which Your Personal Data Shall Be Processed

At our Company, personal data is processed for the purposes of planning and executing commercial activities, planning, supervising and performing occupational health and safety processes, providing authorized institutions and corporations with information required by legislation, managing the recruitment processes of candidate employees, performing obligations towards employees arising from employment contracts and legislation, obtaining technological services in matters outside our field, providing financial agreement with our business partners and / or third parties with respect to our products and services, performing / following up financial reporting and risk management operations, performing / following up legal business and transactions, performing companies and partnerships law procedures, planning and executing the necessary audit activities to ensure the performance of operations in keeping with our Company procedures and applicable legislation, planning and performing corporate sustainability activities, carrying out activities to protect our company's reputation, managing claims and complaints processes, planning and executing corporate governance and communication activities, creating and monitoring visitor records.

Transfer of Your Personal Data

Your personal data shall be processed in compliance with law and in keeping with the principles of integrity, in a manner that is correct and compliant with the above up-to-date, specific, clear and legitimate purposes, connected to the purpose of processing, limited and responsible, and for the period as stipulated in applicable legislation for the purpose for which they are processed. Pursuant to Articles 8 and 9 of the KVKK, your personal data may be transferred to our indirect / direct domestic / foreign affiliates or subsidiaries, domestic / foreign / international, public / private corporations and institutions and other 3rd persons or corporations from which our Company receives services / support / consultancy received or with which our Company cooperates, or with which it acts as project / financing partner, other group companies, other competent institutions and organizations, its suppliers or subcontractors, other concerned persons or corporations permitted by other applicable provisions of legislation, or public and / or private legal entities authorized by law as limited to the requested purpose within its legal competence.

It may also process personal data and share the with third parties without obtaining the Data Owner’s consent in accordance with Articles 5 and 8 of the KVKK and/or in the face of the exceptions provided for in applicable legislation. These circumstances are particularly the following:

Where expressly prescribed by law,

Where this is necessary to protect the life or physical integrity of the concerned or any other person, where the concerned is incapable of declaring their consent due to physical incapacitation, or where their such declaration of consent has no legal validity,

Where it is necessary to process personal data, provided that it is directly related to the establishment or performance of any agreement between the data owner and Marinsa,

Where it is mandatory for the performance of legal obligations,

Where such data are made public by the data owner,

Where the processing of data is mandatory for the institution, exercise or protection of a right,

Where data processing is mandatory for the legitimate interests of Marinsa, provided that the basic rights and freedoms of the data owner are not violated.

The Method And Legal Basis of the Collection Of Personal Data

Your personal data are obtained for the purpose of providing the services offered by the Company within the specified legal framework in line with the above-mentioned purposes through all kinds of oral, written or electronic media, and for ensuring that our Company fully and properly performs its obligations arising from the contract and law. Your personal data collected for this legal purpose may be processed and transferred for the purposes specified in Articles (1) and (2) hereof in accordance with the personal data processing requirements and purposes set out in Articles 5 and 6 of the KVK Law.

Rights of the Personal Data Owner

In the event that you, as personal data owner, communicate your requests relating to your rights through the following methods, our Company shall finalise your request as soon as possible and within no later than thirty (30) days depending on the nature of your request. However, if a fee is stipulated by the Personal Data Protection Board, our Company shall charge the fee identified under such rates.

In this scope, personal data owners shall be entitled to;

Being informed on whether personal data are processed,

Where personal data are processed, requesting information thereon,

Ascertaining the purpose of processing personal data and whether these are used according to their purpose,

Obtaining information on the third persons to whom personal data are transmitted domestically or abroad,

In the event that personal data are processed deficiently or erroneously, requesting the correction thereof, and requesting that the third persons to which personal data are communicated are informed of such procedure,

Where the reasons requiring the processing of personal data cease to exist in spite of such data having been processed in accordance with the provisions of the KVKK and other applicable laws, requesting the deletion or destruction of personal data, and the notification of such procedures to the third parties to which such personal data were transferred.

Objecting to any consequences against the individual through an analysis of processed data exclusively by automatic systems,

Claiming damages in the event that damages are suffered as a result of the unlawful processing of personal data.

You may communicate your request to exercise such rights to us in writing, or in accordance with a different method where such method is identified by the Personal Data Protection Board.

You may exercise your above-mentioned rights by sending your request containing the necessary information confirming your identity and your explanations regarding the right you wish to exercise from among those provided in Article 11 of the KVK Law by completing the “Application Form” found on our website, and by delivering a signed copy of the form to Küçüksu Mah. Ömürtepe Sok.  Kandilli Konakları No:  61  Blok A13  Üsküdar, Istanbul by hand, via notary public, or any other method specified in the KVK Law, or may send such form to kvkk.gdpr@gmail.com as signed with a secure electronic signature.

 Deletion, Destruction or Anonymization of Your Personal Data

Pursuant to Article 7 of the KVK Law, in the event that the reasons justifying the processing of personal data cease to exist despite the fact that the personal data were processed in compliance with applicable legislation, such personal data are deleted, destroyed or anonymized automatically by the Company or upon request of the personal data owner.

The procedures and principles related to this matter shall be performed in accordance with the KVK Law and the Regulation on the Deletion, Destruction or Anonymization of Personal Data published in Official Journal issue 30224 of 28.10.2017.

Personal data shall deleted, destroyed or anonymized within 3 (three) months of the date of our obligation to delete, destroy or anonymize personal data.

When you request the deletion or destruction of your personal data by contacting our company;

a) If all of the conditions requiring the processing of personal data have ceased to exist, your personal data subject to such request shall be deleted, destroyed or anonymized. Your request shall be finalized within thirty (30) days, and you shall be informed.

b) If all of the conditions requiring the processing of personal data have ceased to exist, and the personal data subject to such data was transferred to third parties, the situation shall be communicated to such third parties, and the necessary procedures shall be procured in accordance with the Regulation.

c) If all of the conditions requiring the processing of personal data have not ceased to exist, your request may be rejected with a justification provided pursuant to the third paragraph of Article 13 of the KVK Law, and the rejection reply shall be communicated to you in writing or electronically within no later than thirty (30) days.