Privacy Policy (Personal Data Protection Information Notice)

1. Introduction and Purpose

This Information Notice has been prepared by INDIGOSAIL - Berkay Soydan ("Company", "indigosail", "we") in our capacity as data controller, pursuant to Law No. 6698 on the Protection of Personal Data ("KVKK"), and in particular Article 10 of the Law and the Communiqué on Principles and Procedures for Compliance with the Obligation to Inform, to provide you with information about the personal data we process.

2. Identity of the Data Controller

3. Categories of Personal Data Processed

Depending on the nature of our relationship with you, the following data categories may be processed:

• Identity Data: Name, surname; for foreign nationals, where required, passport number, date of birth and nationality.
• Contact Data: Mobile phone number, WhatsApp number, e-mail address, country/city of residence.
• Legal and Financial Transaction Data: Where required for yacht brokerage or maintenance/repair operations, the vessel's port registry license, registry certificate and related ownership information.
• Request and Transaction Data: Type of service requested (yacht charter, bay tour, transfer, organization, yacht maintenance/repair, brokerage), date and duration preference, number of people, budget range, special notes and preferences, contents of correspondence.
• Marketing and Preference Data: Subscription preferences and consent records in the event that an e-newsletter service is offered in the future.
• Transaction Security and Technical Data: IP address, browser information, device type, date and duration of visit, pages visited, cookie identifiers.

4. Purposes of Processing Personal Data

Your personal data is processed for the following purposes:

• Evaluating and responding to your requests submitted via the website form and WhatsApp,
• Coordinating the yacht charter, bay tour, transfer or organization service you request with the boat owner/operator and initiating the reservation process,
• Directly or indirectly carrying out yacht maintenance, repair and winterization processes and yacht brokerage activities,
• Communicating with you before and after the service, providing price quotations and managing contracting processes,
• Managing customer satisfaction, complaints and feedback,
• Fulfilling our financial, legal and administrative obligations (invoicing, record-keeping, tax legislation, providing information to public authorities when requested),
• Ensuring the security, performance measurement and improvement of the website,
• Sending e-newsletters, campaigns and promotional communications that may be offered in the future, where your explicit consent has been obtained.

5. Legal Grounds for Processing

Your personal data is processed on one or more of the following legal grounds within the scope of KVKK Article 5/2:

• (c) Direct relevance to the establishment or performance of a contract: Coordinating and executing the service you request.
• (d) Necessity for the data controller to fulfill its legal obligations: Record-keeping and notification obligations required by the Tax Procedure Law, Turkish Commercial Code and other legislation.
• (e) Necessity for the establishment, exercise or protection of a right: Constituting evidence in potential disputes.
• (f) Necessity for the legitimate interests of the data controller, provided that fundamental rights and freedoms of the data subject are not harmed: Customer relations management, service quality improvement, website security.

Sending commercial electronic communications is based on your explicit consent pursuant to KVKK Article 5/1. The use of anonymous on-site analytics cookies is processed under the legitimate interest legal basis described in (f) above.

6. Third Parties to Whom Personal Data is Transferred and Transfer Purposes

• Boat owners and/or yacht operators: For the actual delivery of the yacht charter, tour or organization service you request and for completing the reservation.
• Contracted maintenance/repair services and craftsmen: Where the maintenance/repair service is performed via subcontracting, solely for service delivery and vessel/location identification.
• Buyers and sellers: Within the scope of yacht brokerage activities, in order to bring the parties together and establish contact.
• Partner travel agency (if any): With a TURSAB-member travel agency for reservation processes, invoicing and legal obligations.
• Accountant / financial advisor: For invoicing, record-keeping and declaration processes required by tax and financial legislation.
• Legal counsel and attorneys: For defense and protection of rights in the event of a legal dispute.
• IT service providers: For maintaining the website and communication infrastructure, under confidentiality obligations.
• Authorized public institutions: Judicial and administrative authorities that request information/documents pursuant to legislation.

7. International Data Transfers

Due to services provided to foreign nationals and because some IT service providers' servers are located abroad, your personal data may be transferred internationally pursuant to KVKK Article 9, with your explicit consent or within the exceptions provided by the Law. In cross-border transfers, compliance with the protection standards prescribed by the Personal Data Protection Authority is essential.

8. Method and Duration of Data Collection

Your personal data is collected via forms on our website, WhatsApp messages, e-mail, telephone and social media. It is retained for the period necessary for the purposes of processing and is deleted or anonymized at the end of the minimum retention periods prescribed by legislation.

9. Your Rights and Contact

To exercise your rights under Article 11 of KVKK (access, rectification, erasure, etc.), please submit your requests in writing to info@indigosail.com or to Siyavuspasa Mah. Pinar Sk. Suzan Apt. No:6 Bahcelievler/ISTANBUL.