Privacy Policy and GDPR Clarification Text

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Privacy Policy | GDPR Clarification

PERSONAL DATA PROCESSING, PROTECTION, STORAGE, DESTRUCTION
AND
PRIVACY POLICY

DATA CONTROLLER : Marine Mental Management
ADDRESS : Fatih Sultan Mehmet Mah., Poligon Cad. Buyaka 2 Sitesi, Kule 3, D: 1 Tepeüstü Workinton Ofis Ümraniye/İSTANBUL
E-MAIL : info@marinementalmanagement.com

1. PURPOSE AND SCOPE OF THE POLICY

The Personal Data Processing, Protection, Retention and Destruction Policy ("Policy") indicates that the personal data processing, protection, storage, destruction and privacy activities conducted by Fırat YAKA (Marine Mental Management) in accordance with the Personal Data Protection Law No. 6698 ("Law") and other relevant legislation and demonstrate the principles adopted regarding the process.

All practices of processing, storage, destruction of personal data by Fırat YAKA (Marine Mental Management) and protection measures taken for aforementioned personal data are implemented in accordance with privacy policy regarding the matter. However, this policy aims to inform data owners on their rights and applications of said rights.

Scope of the policy; Fırat YAKA (Marine Mental Management) is personal data belonging to visitors, employee candidates and other third parties. The policy applies to all the processing, storage, protection, destruction and privacy activities of personal data owned by Fırat YAKA (Marine Mental Management).

2. PROCESSING OF PERSONAL DATA

2.1 Principles regarding the Processing of Personal Data

Certain principles are stipulated regarding the processing of personal data pursuant to Article 4 of the Law and the provisions of the relevant legislation. Personal data processing activities must be carried out within the scope of these principles. As Fırat YAKA (Marine Mental Management), we carry out all data processing activities according to these principles. Hereby these principles are:

• Processing Of Personal Data Being in Compliance with Law and Good Faith,
• Having Personal Data Accurate and Up to Date When Necessary
• Processing The Personal Data for Specific, Clear and Legitimate Purposes
• Data Being Related, Limited and Restrained with The Purposes That Its Being Collected or Processed,
• Connection, Limited and Measured Personal Data for The Purposes for Which They Are Processed and Data Being Stored Throughout the Necessary Period for The Purpose of Processing or Relevant Legislation.

As Fırat YAKA (Marine Mental Management), we carry out our personal data processing activities in accordance with all these principles; in a way that does not harm fundamental rights and liberties, within the framework of the good faith, taking the necessary measures for the accuracy and up-to-datedness’ of the data. In addition, by clearly determining our purposes for processing personal data, we are in accordance with these purposes and limited to these purposes; we process personal data to the extent necessary in the execution of our business activities. All personal data processed by us are stored for the period required for the purpose for which they are processed or for the periods stipulated in the relevant legislation. 

2.2. Terms for the Processing of Personal Data

We do not process personal data without the express consent of the persons concerned in accordance with the Law and its principles. Cases where explicit consent regarding the processing of personal data will not be sought are shown in paragraph 2 of Article 5 of the Law. (We do not process "Special Quality Personal Data".) Accordingly, there is no obligation to apply for the explicit consent of the persons concerned under the following conditions:

• It's clearly stipulated in the law.
• It is mandatory for the protection of the life or body integrity of the person who is unable to disclose his or her consent due to actual impossibility or whose consent is not legally valid.
• The processing of personal data belonging to the parties to the contract is necessary, provided that it is directly related to the establishment or performance of a contract.
• Processing is necessary for compliance with legal obligations,
• The fact that the contact has been made available to him or her.
• Data processing is mandatory for the establishment, exercise or protection of a right.
• Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

2.3 Personal Data Processing Activities

a. Cookies

Cookies are small text files created by websites on your device that contain data. Cookies enable the website you visit to store information on your device and to use it during subsequent visits to the websites. Cookies created by a website are stored by the internet browser you use to access the site.

The "www.marinementalmanagement.com" website uses cookies and external scripts to improve the user experience – like any website. 

If you visit our home page, a temporary cookie will be set to determine whether your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. These cookies are cookies that are mandatory to use in order for our site to function properly and to benefit from the features of the site and the services offered. Personally identifiable information is not stored through these cookies. In this context, only the visitor's IP address and browser information are collected.

If your browser accepts cookies; In order to facilitate the use of the site and to improve your experience when you visit the site again, some cookies with mandatory, functional and statistical purposes are stored in your browser for a certain period of time and automatically cleared when the statute of limitations occurs.

You can choose to delete cookies stored in your browser through browser settings. (A new cookie will be created when you visit the website again.) You may also block third-party cookies (Google, Facebook) completely through your browser (which will affect your user experience) or choose not to visit this site. (bu durum kullanıcı deneyiminizi etkileyecektir) veya bu siteyi ziyaret etmemeyi tercih edebilirsiniz.

You agree to the use of cookies using our website. When you first visit our website or reset your cookies, we will be notified of our use of cookies. The use of cookies is not mandatory in order to use our website. However, the quality of your user experience may decrease if you set your browser not to accept cookies. Cookies are not used for the purposes specified in this Policy and all relevant transactions are carried out in accordance with data protection legislation.

b. Contact Forms and Other Forms

We process the personal data we process with the contact form -name, surname, contact, address- provided that we make the necessary disclosures and request "consent" pursuant to this Personal Data Policy. 

All our data processing activities are carried out within the scope of this Policy in accordance with the Law. 

c. Embedded Content from Other Sites

Articles on this site may contain embedded content (e.g. videos, images, articles, etc.). Content embedded from other websites behaves exactly the same as if the visitor had visited the other website.

These websites may collect data about you, use cookies, and track things embedded by a third party. This can track your interaction through the embedded content, including tracking your interaction with the embedded content. Data collected through embedded content is not our responsibility and when you access embedded content, the Privacy and Data Collection policies of the third party concerned should be reviewed.

d. Security Data

Our website and contact forms (against potentially offensive threats) are protected by the ReCaptcha service provided by Google in order to ensure security. This service is used for security purposes on many websites. Under the ReCaptcha service, you can use your Google data (see Content embedded from other sites) is to collect independently of us as stated. For more information, please visit the Google Privacy Policy.

e. Analysis

Google Analytics and Facebook Pixel services are embedded on our website to analyze visitors and guide their marketing strategies. In this case, the conditions in the section titled"Content Embedded from Other Sites" apply exactly. Data collected through external scripts are stored by third-party service providers and may be used by us.

In addition, all data we collect "with consent" through contact forms and other forms are stored by "us" for the periods stipulated in the law. 

3. DISCLOSURE OF PERSONAL DATA OWNERS 

During the acquisition of personal data in accordance with Article 10 of the Law and the provisions of the relevant legislation:

• The identity of our representative and us,
• For what purpose personal data will be processed,
• To whom and for what purpose the processed personal data can be transferred,
• Method and legal reason for collecting personal data,
• Rights of the person concerned (rights contained in Article 11 of the Law.) it fulfills its disclosure obligation by informing the relevant persons about its issues.

(You can click here to access the Data Information Disclosure.)

4. SHARING PERSONAL DATA WITH THIRD PARTIES 

Your personal data for the purpose of performing obligations to the law and related parties; to be shared with public institutions/organizations and financial (bank, etc.) organizations. Your personal data is not transferred abroad.

5. RETENTION TIME AND DESTRUCTION OF PERSONAL DATA

The personal data processed by us are retained for the period stipulated in the relevant legal regulations, limited to the time required for processing purposes. Accordingly, we determine whether a period of time is foreseen for the storage of personal data in the relevant legislation and personal data are stored in accordance with this period if a period has been specified. In the relevant legislations, in the absence of a period of time for the relevant personal data, the personal data are stored for the period necessary for the purposes for which they are processed. 

Personal data at the end of the retention periods specified in the direction mentioned above in accordance with periodic destruction periods or data subject application and the specified methods of destruction; it is destroyed in accordance with Article 7 of the Law by means of deletion, destruction or anonymization.

6. TRANSFER OF PERSONAL DATA

Pursuant to Articles 5 and 8 of the Law and related provisions, we take into account the existence of the explicit consent of the User concerned as a basic principle regarding the transfer of personal data in the process of personal data. However, the following conditions shown by paragraph 2 of Article 8 of the Law do not seek the explicit consent of the persons concerned in the transfer of personal data:

• It's clearly stipulated in the law.
• It is mandatory for the protection of the life or body integrity of the person who is unable to disclose his or her consent due to actual impossibility or whose consent is not legally valid.
• The processing of personal data belonging to the parties to the contract is necessary, provided that it is directly related to the establishment or performance of a contract.
• Processing is necessary for compliance with legal obligations,
• The fact that the contact has been made available to him or her.
• Data processing is mandatory for the establishment, exercise or protection of a right.
• Data processing is mandatory for our legitimate interests, provided that it does not harm the fundamental rights and freedoms of the person concerned.
• In cases where the explicit consent of the persons concerned is not sought in the special quality personal data mentioned in Article 2.1 of this Policy, data transfer activities can be carried out without the explicit consent of the persons concerned. 
  
  

7. PROTECTION AND SECURITY OF PERSONAL DATA

Pursuant to Article 12 of the Law:

• To prevent unlawful processing of personal data,
• To prevent unlawful access to personal data,
• It takes all kinds of technical and administrative measures to ensure security in order to ensure the storage of personal data. Within the scope of all this, the necessary audits are carried out by us. 
  
  

8. YOUR RIGHTS CONCERNING YOUR DATA BEING COLLECTED AND THE USE OF THIS RIGHTS

In accordance with Article 11 of the Law, persons with personal data have the following rights:

• Learn whether your personal data is processed,
• If personal data is processed request information about personal data,
• Learn the purpose of processing data and if they are used for the purposes specified,
• If any, find out the third parties it is being shared with domestically and abroad and the data being shared,
• Request rectification of the processed personal data which is incomplete or inaccurate and to request notification of the transaction carried out within this scope to third parties to whom the personal data are transferred,
• Request erasure or destruction of data in case of elimination of the reasons requiring its processing, even though it has been processed in accordance with the law no. 6698 and other relevant law provisions, and to request that the transaction carried out within this scope be notified to the third parties to whom the personal data are transferred,
• Object to negative consequences about the person himself that are concluded as a result of analysis of the processed personal data by solely automatic means
• Demand compensation for the damages of person who has suffered as a result of an unlawful processing operation. 
  

As personal data owners, you can submit your claims for your rights by filling out the “Kişisel Veri Bilgi ve Talep Formu” on the website (“www.marinementalmanagement.com”) ; if you send the file to the above maritime psychology address by e-mail signed with your personal secure electronic signature or if you send the file with the extension "Word or PDF" by e-mail to (“info@marinementalmanagement.com”) e-posta ile göndermeniz halinde; or if you hand-deliver it to our address written above; Fırat YAKA (Marine Mental Management) will finalize the request free of charge as soon as possible and within thirty days at the latest according to the nature of the request. However, if the transaction requires a separate cost except for the legal requirements free of charge, a fee may be charged by Fırat YAKA (Marine Mental Management) at the tariff determined by the Personal Data Protection Board.

9. DATA PROCESSING PURPOSES

In accordance with the processing requirements stipulated by the Law, the personal data of our customers are processed for the following purposes:

• Managing activities for customer satisfaction,
• Product sales and execution of support services during/after the service provided,
• Follow-up of requests and complaints,
• Conducting financial and accounting affairs,
• Execution and supervision of business activities,
• Ensuring physical space safety,
• Fulfilling legal obligations and exercise of rights arising from applicable legislation.
  
  

10. PERSONAL DATA HOLDERS WHOSE DATA IS PROCESSED BY OUR COMPANY

ACCORDING TO THE LAW NO. 6698 PROTECTION AND PROCESSING OF VISITOR AND EMPLOYEE CANDIDATE
DATA INFORMATION DISCLOSURE

DATA CONTROLLER : Marine Mental Management
ADDRESS : Fatih Sultan Mehmet Mah., Poligon Cad. Buyaka 2 Sitesi, Kule 3, D: 1 Tepeüstü Workinton Ofis Ümraniye/İSTANBUL
E-MAIL : info@marinementalmanagement.com

INTRODUCTION

The Law no. 6698 on the Protection of Personal Data ("KVKK") was published in the “Official Gazette” dated 07.04.2016 and regulations, board decisions, etc. were published in terms of the implementation of this Law. In general, the KVKK regulates the rights of individuals in the processing of personal data, the procedures and principles that real and legal persons who process personal data will comply with their obligations. According to article 10 of the KVKK, at the time of obtaining personal data, disclosure should be made to the persons concerned by the data controller or authorized persons. Pursuant to this provision and the first paragraph (e) of article 22 of the KVKK, the Communiqué on the Procedures and Principles to be Applied in the Fulfillment of the Disclosure Requirement ("Communiqué") was prepared by the Personal Data Protection Board ("Board") and the communiqué has been published in the Official Gazette dated March 10, 2018, and numbered 30356. The framework of your obligations and your rights under the KVKK and all these regulations are presented to your information within the scope of this disclosure text. 

As data controller Fırat YAKA (Marine Mental Management), we declare that personal data of persons under the service scope (website visitors and employee candidates) may be recorded, stored, retained and shared with the institutions authorized by law to solicit personal data; aforementioned data may be transferred, delegated, organized and subjected to other processes mentioned in KVKK with third parties within the scope of this disclosure. In case the written conditions in the KVKK and The Extermination Policy are fulfilled by relevant users, processed personal data may be destroyed, deleted, or anonymized and destroyed.

1. YOUR PROCESSED PERSONAL DATA

Personal Data: Any information that Fırat YAKA will obtain within the scope of this directly or indirectly indicates the identity of the website visitors and employee candidates as a result of being associated with any record. 

Personal data of website visitors and employee candidates that can be processed by me as Fırat YAKA (Marine Mental Management): - first name, surname, communication, address, T.C. identification number, education information, study information, reference information, photo- information.

2. PURPOSES FOR WHICH PERSONAL DATA SHALL BE PROCESSED

Within the scope of Article 10 of the KVKK and Article 5 of the Communiqué, the personal data of website visitors and employee candidates can be processed for the purposes we indicate below pursuant with the processing conditions specified in Article 4 of the KVKK :

• Conducting information and form procedures,
• Execution of the application processes of the candidates,
• Determination of the eligibility to work of the employees,
• Managing activities for the satisfaction of website visitors,
• Execution of support services during/after the service provided,
• Follow-up of requests and complaints,
• Conducting communication activities,
• Execution and supervision of business activities,
• Fulfilling legal obligations and exercise of rights arising from applicable legislation.
  

3. METHOD AND LEGAL REASON FOR COLLECTING YOUR PERSONAL DATA

Your personal data can be obtained directly from third parties and legal authorities during Legal relationship establishment, recruitment management, form filling such as communication, etc. Here, personal data obtained through written or oral communication channels may be collected from oral, written or electronic media. We conduct these processes to fulfill our obligations arising from the law in accordance with all relevant legislations in a complete and accurate manner during the execution of our services.

In accordance with Article 5 of the KVKK, personal data cannot be processed without the express consent of the person concerned. Exceptions in which explicit consent is not required are specified by law. "Provided that ; there is a clear provision in the law, that it is directly related to the establishment or performance of a contract, the processing of personal data belonging to the parties to the contract is necessary, it is mandatory for the company to fulfill its legal obligation, it is publicized by the person concerned, data processing is mandatory for the establishment, use or protection of a right, and does not harm the fundamental rights and freedoms of the person concerned, data processing is mandatory for the legitimate interests of the data controller" in this context personal data can be processed by Fırat YAKA (Marine Mental Management) without seeking explicit consent. Within the scope of the methods and purposes of processing personal data and in accordance with the principles and procedures stipulated by the relevant legislation, the data may be processed for the above-mentioned legal reasons and within your express consent in order to achieve the objectives specified in this disclosure and to fulfill legal obligations.

4. PERSONAL DATA RETENTISION TRADE

Pursuant to Personal Data Protection Law, your personal data processed for the purposes specified in this disclosure will be deleted, destroyed or anonymized by us when the purpose requiring processing in accordance with article 7/f.1. of the KVKK disappears and/or the periods we are required to process your data in accordance with the legislation expire, considering the Personal Data Retention and Destruction Policy.

5. SHARING THE PERSONAL DATA WITH THE THIRD PARTY 

Marine Mental Management may share your personal data to perform its obligations to the law and related parties with public institutions. Your personal data is not transferred abroad. 

6. YOUR RIGHTS UNDER ARTICLE 11 OF THE KVKK 

As personal data owners, you can submit your claims for your rights by filling out the “Kişisel Veri Bilgi ve Talep Formu” on the website (“www.marinementalmanagement.com”) ; if you send the file to the above Marine Mental Management address by e-mail signed with your personal secure electronic signature or if you send the file with the extension "Word or PDF" by e-mail to (“info@marinementalmanagement.com”) or if you hand-deliver it to our address written above; Fırat YAKA (Marine Mental Management) will finalize the request free of charge as soon as possible and within thirty days at the latest according to the nature of the request. However, if the transaction requires a separate cost except for the legal requirements free of charge, a fee may be charged by Fırat YAKA (Marine Mental Management) at the tariff determined by the Personal Data Protection Board. In this context, personal data subjects:

• Learn whether your personal data is processed,
• If personal data is processed request information about personal data,
• Learn the purpose of processing data and if they are used for the purposes specified,
• If any, find out the third parties it is being shared with domestically and abroad and the data being shared,
• Request rectification of the processed personal data which is incomplete or inaccurate and to request notification of the transaction carried out within this scope to third parties to whom the personal data are transferred,
• Request erasure or destruction of data in case of elimination of the reasons requiring its processing, even though it has been processed in accordance with the law no. 6698 and other relevant law provisions, and to request that the transaction carried out within this scope be notified to the third parties to whom the personal data are transferred,
• Object to negative consequences about the person himself that are concluded as a result of analysis of the processed personal data by solely automatic means
• Demand compensation for the damages of person who has suffered as a result of an unlawful processing operation. 
  
  

7. EXCEPTIONS

In accordance with Article 28 of the Personal Data Protection Law, personal data owners will not be able to assert their rights in the following matters. 

• Processing of personal data for purposes such as research, planning and statistics by anonymizing them with official statistics,
• Processing of personal data for artistic, historical, literary or scientific purposes or within the scope of freedom of expression, provided that it does not violate national defense, national security, public safety, public order, economic security, privacy or personal rights or constitute a crime, 
• Processing of personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations authorized by law to ensure national defense, national security, public safety, public order, economic security, 
• Processing of personal data by judicial authorities or execution authorities in relation to investigation, prosecution, trial or execution procedures in accordance with Article 28/2 of the Law; personal data owners will not be able to assert their rights, except to request damages in the following cases, 
• Personal data processing is necessary for the prevention of criminal or criminal investigation, 
• Processing of personal data made available by the personal data subject himself, 
• Personal data processing is necessary for the conduct of auditing or regulation duties by authorized public institutions and organizations and professional institutions that are public institutions on the basis of the authority granted by the law, and for disciplinary investigation and prosecution, 
• Personal data processing is necessary for the protection of the economic and financial interests of the state in relation to budget, tax and financial issues.