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Policies and terms

CLARIFICATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

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Contents

1. Data Controller

Data controller under the Law on the Protection of Personal Data No. 6698 (“KVKK”):

CELALOĞLU GROUP TURİZM VE SAĞLIK HİZMETLERİ TİC. LTD. ŞTİ.

Tax Office: Kağıthane Tax Office Tax No: 4781119609

Trade Registry No: 413483-5 MERSİS No: 0478111960900001

Address: İzzetpaşa Mah. Yeniyol Cad. No:14 Daire:7 Şişli / İSTANBUL

TÜRSAB No: 15101 Web: www.teknepro.com

E-mail: [email protected]

Hereinafter, the company shall be referred to as “TeknePro”, “Company”, “We” or “Data Controller”.

2. Purpose of the Clarification Text

This text has been prepared to inform individuals visiting the TeknePro website, creating a membership, renting a boat, making a reservation,

receiving information about a reservation, contacting TeknePro, benefiting from customer services,

listing their boat on the TeknePro platform, or being a boat owner/operator regarding the scope in which their personal data is processed.

3. Processed Personal Data

Depending on the nature of the service, identity, contact, reservation, finance, transaction security, customer transaction, and boat

owner/operator information may be processed. These may include first-last name, phone, e-mail, address, reservation and PAX

information, payment/invoice information, IP and log records, device/browser information, call center and communication

records, boat and business information, as well as information contained in necessary documents.

4. Purposes of Processing Personal Data

Personal data may be processed for the purposes of carrying out membership and reservation transactions, providing boat rental services,

reservation change/cancellation/refund procedures, meeting customer requests, managing operations with boat owners,

payment and invoicing, customer services, information security, preventing fraud and

abuse, fulfilling legal obligations, conducting legal processes,

developing the platform, and, subject to necessary legal conditions, marketing activities.

5. Legal Grounds for Processing Personal Data

Data may be processed based on one or more of the legal grounds specified in Article 5 of the KVKK depending on the concrete processing activity: being explicitly

stipulated by law, being necessary for the establishment or performance of a contract, legal obligation, publicization, the

establishment/exercise/protection of a right, legitimate interest of the data controller, or explicit consent

when necessary. Explicit consent is not automatically obtained for every transaction.

6. Special Categories of Personal Data

In the event that the processing of special categories of personal data is required during the execution of TeknePro services,

such data shall be processed in accordance with the relevant provisions of the KVKK. Unless mandatory for the provision of the service,

such data will not be requested.

TeknePro | www.teknepro.com | [email protected] Page 17. Parties to Whom Personal Data May Be Transferred

Data may be transferred to authorized TeknePro employees, relevant boat owners/operators, service

providers necessary for completing the reservation, payment institutions and banks, accounting/financial

advisory and legal service providers, information technology/hosting and call center service

providers, and legally authorized public institutions and judicial authorities, limited to the purpose and to the extent necessary.

8. Data Sharing with Boat Owners

To fulfill the reservation, necessary customer information may be shared with the relevant boat owner or

operator. Sharing is limited to the information necessary to provide the service.

9. Cross-Border Data Transfer

If third-party technology services used by TeknePro are located abroad, transferring personal

data abroad may be in question. Such a transfer is carried out in compliance with the current conditions regulated in Article 9 of the KVKK.

The services used and actual data flows are evaluated separately.

10. Methods of Collecting Personal Data

Personal data may be collected through electronic or physical methods such as the www.teknepro.com website, membership and reservation forms, phone, e-mail,

WhatsApp, customer services, face-to-face communication, boat owners, payment systems, and cookies.

11. Cookies

Necessary cookies may be used on the TeknePro website. For non-essential cookies intended for analytics, performance, advertising, and targeting,

necessary legal mechanisms are applied according to the technology used, and appropriate choice options are offered to the user.

12. Commercial Electronic Messages

In case messages are sent for advertising and promotional purposes via channels such as SMS, e-mail, WhatsApp, phone, or push notifications,

necessary permission and consent processes are conducted separately under the relevant legislation.

13. Retention Period of Personal Data

Personal data is stored for the periods stipulated in the relevant legislation, the continuation of the contractual relationship, the

statute of limitations required for legal disputes, and the duration required by the processing purpose. Upon expiration of the period,

data is deleted, destroyed, or anonymized in accordance with the legislation.

14. Data Security

TeknePro takes necessary technical and administrative measures to prevent unauthorized access, data loss, and unauthorized alterations, and to ensure information security.

In the event of a personal data breach, obligations stipulated in the legislation are fulfilled.

15. Rights of the Data Subject

Under Article 11 of the KVKK, the data subject has the right to learn whether their personal data is processed, request information,

learn the purpose of processing, know the third parties to whom data is transferred, request correction, request deletion/destruction when legal conditions

are met, request notification of the actions taken to third parties, object to results derived exclusively from automated analysis,

and demand compensation for damages due to unlawful processing.

TeknePro | www.teknepro.com | [email protected]

16. Application

Requests under the KVKK may be submitted to Celaloğlu Group Turizm ve Sağlık Hizmetleri Tic. Ltd. Şti.’s address at İzzetpaşa

Mah. Yeniyol Cad. No:14 Daire:7 Şişli / İSTANBUL or to the [email protected] e-mail address,

in accordance with the application procedures stipulated in the legislation.

17. About the Clarification Text

This text has been prepared to fulfill the obligation to inform regarding the processing of personal data.

Reading or accepting this text does not mean that explicit consent has been granted in every case. For transactions requiring explicit consent, separate

and specific explicit consent texts are used.