K.V.K.K.K. POLICY

WESTHAN YACHT LIMITED COMPANY (“Company”) explains the principles for the processing of personal data that should be known by real person users whose personal data we process on our website. This policy provides information about the personal data you share with us during the login and membership of our valued users to our website, for what purpose this data is processed, for what purpose and to whom your personal information we process can be transferred, the method and legal reason for collecting personal data, the obligations of our party regarding personal data collection, the rights of our valued users and other issues.

INTRODUCTION

First and foremost, we would like to emphasize that as WESTHAN YACHT LIMITED COMPANY, we have built our company policy on trust and loyalty.

In this context, we undertake that we protect your personal data that you have shared with us with high security software.

As WESTHAN YACHT LIMITED COMPANY, we inform you, our valued users, that your personal data you have shared with us are protected and secured based on confidentiality principles within the scope of K.V.K.K.

WHAT IS PERSONAL DATA?

Any information relating to an identified or identifiable natural person is called personal data. For example, data that provide accurate identification of the individual such as name, surname, date of birth, place of birth and data regarding the physical, family, economic, social and other characteristics of the person are within the scope of personal data.

WHAT DOES IT MEAN TO PROCESS PERSONAL DATA?

Any operation performed on personal data such as obtaining, recording, storing, retaining, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic means or by non-automatic means provided that it is part of any data recording system is the processing of personal data.

WHAT IS THE PERSONAL DATA WE COLLECT?

First of all, we would like to state that we undertake that we will not use your personal data that you share except for the purposes stated in the section “Our Purposes of Using Personal Data”.

The personal data we receive from you, our valued users, are used in accordance with our policy.

Personal data we collect from our site visitors/users;

• Identity information (name-surname, ID number)
• Contact information (e-mail address, phone number, address)
• In particular, indirect information such as log records, cookies, connection and system information, etc. data are processed by us.

WHY SHOULD YOU SHARE THIS DATA WITH US?

In order for us to provide you with better and higher quality service, your sharing your personal data with us for the purpose of communicating directly or by e-mail, customer satisfaction, contacting you directly by e-mail marketing, evaluating your complaints and requests, etc. enables us to provide you with better service.

WHAT IS THE PURPOSE OF OUR USE OF YOUR PERSONAL DATA?

Your personal information;

• Communicate more effectively,
• Providing our users/visitors with the most beneficial use of our website,
• Providing services to our users/visitors in the light of the information they provide,
• Assisting in the creation, development, use, delivery and improvement of our services, content and advertising, as well as loss and fraud prevention,
• Account and network security, including for the purpose of securing our Services for the benefit of all our users,
• Verifying information provided by you from publicly available sources for certain online transactions,
• Verify your identity, help authenticate users and identify appropriate services,
• Auditing, data analysis and research to improve our site
• Providing information about our campaigns,
• Providing information upon request by public institutions and organizations

We can use it for its intended purpose.

TRANSFER OF PERSONAL DATA

WESTHAN YACHT LIMITED COMPANY may transfer data upon the requests of legal authorities and authorities by taking the necessary security measures in line with the purposes of personal data processing. In this context, our Company may transfer personal data only within the scope of the regulations stipulated in Articles 8 and 9 of the Law on the Protection of Personal Data. Except for the regulations stipulated in Articles 8 and 9 of the Law on the Protection of Personal Data, your personal data will not be shared with any institution other than our company.

LEGAL BASIS AND GENERAL PRINCIPLES

While personal data is primarily protected under the Constitution, it is also regulated under Law No. 6698, Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed through These Publications, Law No. 6563 on the Regulation of Electronic Commerce and related secondary legislation.

The Turkish Penal Code No. 5237 also provides for a number of criminal sanctions for the protection of personal data.

On the other hand, it is necessary to collect and use personal data in order to fulfill our obligations arising from the Consumer Protection Law No. 6502 and the Regulation on Distance Contracts.

In order to take necessary measures to protect privacy and to comply with all legal principles regarding the processing of personal data; our Company processes personal data in accordance with the principles listed below within the framework of the purposes specified in this Policy:

• Compliance with the law and good faith,
• Being accurate and up to date when necessary,
• Processing for specific, explicit and legitimate purposes,
• Being relevant, limited and proportionate to the purpose for which they are processed,
• Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

CLARIFICATION AND INFORMATION OF THE PERSONAL DATA SUBJECT

WESTHAN CAPITAL EĞİTİM DANIŞMANLIK LİMİTED ŞİRKETİ enlightens personal data subjects during the acquisition of personal data in accordance with Article 10 of the K.V.K.K. (You can access the “Clarification Text” on our website).

In this section, personal data owners are informed about the rights of the personal data owner in accordance with subparagraph d of Article 10 of the K.V.K.K.

As a data subject, pursuant to Article 11 of the LPPD; everyone can apply to the data controller and submit a request to the data controller,

• learn whether their personal data is being processed,
• request information if personal data has been processed,
• to learn the purpose of processing personal data and whether they are used in accordance with their purpose,
• to know the third parties to whom their personal data are transferred domestically or abroad,
• to request correction of personal data in case of incomplete or incorrect processing,
• to request the deletion or destruction of personal data in the event that the reasons requiring their processing disappear,
• to request notification of correction and deletion to third parties to whom personal data are transferred,
• object to the emergence of a result that is to your detriment by analyzing the processed data exclusively through automated systems,
• to demand compensation for damages in case of damage due to unlawful processing of personal data

rights.

In this context, WESTHAN YACHT LIMITED COMPANY undertakes to provide the necessary information in the event that the personal data owner requests information in accordance with both the “Right to Information”, which is a constitutional right, and this K.V.K.K. provision.

If you wish to exercise any of the above-mentioned rights as a data subject, you must submit a petition stating your application to our address information on the website in person or through a notary public or send it to our e-mail address with your secure electronic signature.

Your applications and requests will be evaluated and finalized within thirty days at the latest, depending on the nature of the request within the scope of Article 13 of the K.V.K.K.

Positive or negative responses to requests from data subjects may be notified to data subjects in writing or electronically.

Although the requests of data subjects will be finalized free of charge as a rule, if the response to the request requires an additional cost, a fee may be charged in the amounts determined within the framework of the relevant legislation.

CONDITIONS FOR DELETION, DESTRUCTION AND ANONYMIZATION OF PERSONAL DATA

• Although it has been processed in accordance with the provisions of the relevant law as regulated in Article 138 of the Turkish Penal Code and Article 7 of the KVK Law, personal data is deleted, destroyed or anonymized upon our company’s own decision or upon the request of the personal data owner if the reasons requiring its processing disappear.
• Log records are shared only with the employees working in the relevant department of our company and the company from which we receive website services, and a limited number of people who have access to these records declare that they will protect the confidentiality of the data they access with a confidentiality undertaking.
• If you terminate your membership, your personal data may be deleted immediately upon your request, or in any case, it will be deleted within the periods specified in the legal legislation.

IMPLEMENTATION OF THE POLICY AND RELEVANT LEGISLATION

The relevant legal regulations and legislation will be applied primarily in matters such as processing/anonymization of your personal data. In case there are parts where this Policy and the relevant legislation do not comply with the relevant legislation, the relevant legal regulations and legislation will be applied.

WESTHAN YACHT LIMITED COMPANY reserves the right to update this Personal Data Protection Policy at any time within the framework of the changes that may be made in the legislation in force in case of issues such as the change / regulation of legal legislation.

Izmir Courts and Execution Offices are authorized in any dispute related to the Policy. Users are deemed to have accepted the authority of Izmir Courts and Execution Offices in terms of jurisdiction by approving this policy.

IN ACCORDANCE WITH THE LEGISLATION ON THE PROTECTION OF PERSONAL DATA TEXT OF EXPLICIT CONSENT

ULAMIŞ MAH. 1419/5 SK. registered to İzmir Trade Registry Directorate with the number 226608 in the capacity of data controller. NO: 12 SEFERİHİSAR / İZMİR, as WESTHAN YACHT LIMITED COMPANY (“COMPANY”), we request your explicit consent regarding the following issues for the purpose of processing and / or transferring your personal data, except for the cases that fall within the exception of the obligation to obtain explicit consent stipulated for the processing and transfer of personal data within the scope of the Personal Data Protection legislation (for example, if it is stipulated by law or required for the performance of the contract):

Recording of my personal data consisting of my identity data, communication data, audio/visual data, financial data, professional data, transaction security data, legal transaction data, data within the scope of physical space security, and signature data, and my personal data of special nature, as long as the contract continues and in any case for the legal retention periods determined within the framework of the relevant Law, I hereby declare that I have been provided with the necessary information in accordance with Article 10 of the Personal Data Protection Law regarding the processing, storage and transfer of my personal data, as well as the deletion, destruction or anonymization of my personal data in accordance with the relevant Law and related sub-legal regulations in the event that the legal retention period expires. I have been informed according to Article 10 of the Personal Data Protection Law,

I hereby declare thatI have read and understood the K.V.K.K. POLICY and the DISCLOSURE TEXT published on the official website of the COMPANY (www.westhanyacht.com), and I hereby declare this “Explicit Consent Declaration” without being under any influence or pressure. I hereby accept, declare and undertake that I explicitly consent to the collection, recording, processing, storage and transfer of my personal and sensitive personal data specified above in the text by the COMPANY.

I hereby declare that I have been informed by the Company with the Clarification Text and that I knowingly and willingly consent to the aforementioned matters.

CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA

This Clarification Text has been prepared by WESTHAN YACHT LIMITED COMPANY (““Company“”) in order to inform the Company’s customers about the processing of their personal data by the Company within the scope of the Law No. 6698 on the Protection of Personal Data (“Law“). This Clarification Text explains the scope of processing of your personal data collected within the framework of your contractual relationship with our Company.

Detailed information regarding the processing of your personal data within the scope of this Clarification Text can be found in the K.V.K.K. Policy at[www.westhanyacht.com].

1-DATA OFFICER:

Your personal data is processed by WESTHAN YACHT LİMİTED ŞİRKETİ (“Company”), which is registered with İzmir Trade Registry Directorate with the number 226608 as the data controller and operates at ULAMIŞ MAH. 1419/5 SK. NO: 12 SEFERİHİSAR / İZMİR, within the scope of the provisions of the Personal Data Protection Law No. 6698 (“KVKK”) and within the framework of this Clarification Text.

2-PURPOSES OF PROCESSING PERSONAL DATA:

Your personal data, within the framework of the personal data processing conditions specified in Articles 5 and 6 of the Law:

• To fulfill our legal obligations arising from the contract,
• Communicating more effectively with our customers,
• To provide service to our customers in the light of the information they provide,
• Planning and execution of the activities necessary to recommend and promote the products and services offered by the Companyto the relevant persons by customizing them according to their tastes, usage habits and needs,
• Ensure account and network security, including to safeguard our Services for the benefit of all our users,
• Planning and execution of the Company’scommercial and/or business strategies,
• Execution of Finance and Accounting Affairs, Follow-up and Execution of Legal Affairs, Execution of Communication Activities, Execution of Goods / Service Procurement Processes,
• Conducting audits, data analysis and research to improve our site,
• To fulfill our obligations under the V.K.K. and other relevant legislation, within this scope

Providing information upon request of public institutions and organizations,

• To keep you informed about our company’s campaigns, innovations and developments

Your personal information is collected and processed for these purposes.

3-PERSONS TO WHOM YOUR PERSONAL DATA MAY BE TRANSFERRED AND THE PURPOSES OF TRANSFER:

Within our Company, your personal data can only be accessed to the extent necessary for the purposes described above.

Your personal data may be shared with the places explicitly authorized by the legislation and the authorized authorities upon their request within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law, within the scope of the legal obligation of the data controller, legitimate interest and the establishment, use or protection of a right, within the scope of personal data processing conditions (legal reasons). In addition, upon a court decision and upon the request of an administrative authority expressly authorized by law, it may be shared with the authorized person or institution.

4- METHOD AND LEGAL GROUNDS FOR COLLECTING PERSONAL DATA:

Your personal data is collected electronically by our Company through our website. This personal data includes all personal data provided directly by you, our customers, in forms such as application form/membership form/contact form/campaign form as a result of their positive actions to www.westhanyacht.com. For example, name-surname, contact information, identity information are included in such data.

When you use our website, during the service provided to you, personal data regarding the usage habits of the customers are also collected by means of certain software or technological tools. For example, location data and favorites as well as interests and usage data are included in such data.

In addition, we use cookies on our website for various purposes and process your personal data through these cookies. Cookies, It may be processed for the purposes of performing the basic functions necessary for the operation of the site, analyzing the site and improving the performance of the site, increasing the functionality of the site and providing ease of use, personalization, targeting and advertising activities. On our site:

• Mandatory cookies (such as authentication cookies that are mandatory for our site to function correctly, such as authentication cookies that are activated when you log in.)
• Functionality and preference cookies (Cookies that remember your preferences and choices on the site and personalize the services offered on our site for you, for example, cookies that remember the visitor’s language preference or text font size selection).
• Social media cookies (Cookies that collect information about your social media usage)
• Performance and analysis cookies (Cookies that help to improve our site, about the use of the site, to analyze the performance of the site, to check whether our site is working properly)
• Targeting and advertising cookies (Cookies used to promote products and services on our site or in channels other than our site)

Your personal data is collected within the scope of personal data processing conditions (legal reasons) regulated in Articles 5 and 6 of the KVKK for the establishment or performance of the contract, legitimate interest, legal obligation and the establishment, use or protection of a right.

5-YOUR RIGHTS UNDER THE K.V.K.K:

As a personal data subject, we inform you that you have the following rights pursuant to Article 11 of the PDP Law.

Article 11 of the P.V.K.K:

Everyone can apply to the data controller;
a) Learn whether personal data is being processed,
b) Request information if personal data has been processed,
c) To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
ç) To know the third parties to whom personal data are transferred domestically or abroad,
d) To request correction of personal data in case of incomplete or incorrect processing,
e) To request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7,
f) To request notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data are transferred,
g) To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
ğ) In case of damage due to unlawful processing of personal data, to demand compensation for the damage

rights.

Pursuant to Article 13 of the KVKK Law, you can submit your applications to exercise your rights mentioned above to our Company in accordance with the provisions of the Communiqué on the Procedures and Principles of Application to the Data Controller (in writing or electronically via registered electronic mail (KEP) address, secure electronic signature, mobile signature or your e-mail address that you have previously notified to our Company and registered in our systems, together with the information/documents* (T.C. identification number or passport number for citizens of other countries, residential address/workplace address for notification, mobile phone/telephone/fax number, e-mail address, etc.) to our Company. Depending on the nature of your request, your applications will be finalized free of charge as soon as possible and within 30 (thirty) days at the latest; however, if the transaction requires an additional cost, you may be charged a fee according to the tariff to be determined by the Personal Data Protection Board.

* We would like to remind you that no special categories of personal data (e.g. religious information or blood type information) should be included within the scope of these documents.