The purpose of this policy is to make a statement about the Personal Data Processing activities and related systems carried out lawfully by EMPIRE YACHT MANAGEMENT as the KVKK Data Controller; To inform Relevant Persons and thus provide transparency regarding Personal Data. In this context, our Company has detailed its Personal Data processing activities within the scope of KVKK and the rights of the Relevant Persons subject to Personal Data Processing in this Policy.
Regular control and follow-up operations regarding the issues within the scope of the policy will be carried out according to the performance tracking and monitoring criteria to be established by our Company.
Our company adopts the following principles regarding the processing of Personal Data, in accordance with the 2nd paragraph of Article 4 of the KVKK and within the scope of the purposes specified in the ‘Purposes of Processing Personal Data’ section of this Policy;
Complying with the law and the rules of honesty,
Being accurate and up to date when necessary,
Processing for specific, clear and legitimate purposes,
Being related to the purpose for which they are processed, being limited and proportionate,
To be kept for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed.
DATA PROCESSED BY OUR COMPANY
Personal Data is processed within our Company through the Explicit Consent received from Relevant Persons or in the light of activities that do not require Explicit Consent under Articles 5 and 6 of the KVKK, and these data are processed only within the framework of the purposes specified in the ‘Purposes of Processing Personal Data’ section of this Policy. The categories of Personal Data that vary and differentiate depending on the type and nature of the relationship between our Company and the Relevant Person, the communication channel used and the purpose of Processing Personal Data and are processed in accordance with the principles in this Policy are generally as follows:
Other promotional information specific to the products owned by the person,
Data contained in identification documents,
Personal identifying information created by our company,
Information regarding asset status,
Personal data stored for authentication purposes,
Hardware digital data obtained for customer identification purposes,
Contact information and records,
Real person information in documents for legal entities,
Descriptive and qualitative information about candidates and employees produced by our Company,
Detailed financial data regarding the transactions carried out on our company’s channels.
These data are defined on VERBIS through the Personal Data Inventory.
PURPOSES OF PROCESSING PERSONAL DATA
Personal Data may be processed by our Company within the scope of the purposes exemplified below and may be stored for as long as these purposes and the relevant legal periods stipulate;
Continuing the activities of our company completely,
Carrying out activities within the scope of legal and administrative obligations,
Negotiation, creation and execution of contracts,
Providing support to the Relevant Person within the scope of requests and questions,
Carrying out promotional and marketing activities,
Obtaining the opinions of Relevant Persons through surveys and voting and ensuring customer satisfaction,
Determination of product groups that appeal to the customer,
Risk analysis studies carried out by our company in accordance with risk criteria,
Making improvements for the needs of our customers and our company,
Conducting candidate evaluation and recruitment processes
Our company carries out human resources management,
Planning and execution of corporate sustainability activities,
Carrying out commercial activities for the purpose of carrying out business partnerships of our company and its subsidiaries,
These purposes are detailed on VERBIS through the Personal Data Inventory.
TRANSFER OF PERSONAL DATA
Our company transfers data to customers, suppliers and business partners within the framework of the purposes exemplified in the ‘Purposes of Processing Personal Data’ section of this Policy and in accordance with Articles 8 and 9 of the KVKK, and Personal Data can be processed and stored in the servers and electronic environments used in this context.
COLLECTION OF PERSONAL DATA
In order to meet the purposes exemplified in the ‘Purposes of Processing Personal Data’ section of this Policy, our company directly receives information from employees and customers, suppliers, business partners, affiliates, call center, live support channel, branches, e-mail, within the framework of the conditions foreseen in Articles 5 and 6 of the KVKK. Personal Data can be collected from branches, official institutions, ATMs and e-toll booths and other physical environments, as well as through websites, mobile applications, social media and other public channels or organized trainings, organizations and similar events.
STORAGE PERIOD OF PERSONAL DATA
Personal Data is stored within our Company, during the relevant legal retention periods or as necessary to carry out the activities related to this data and the purposes specified in this Policy.