PRIVACY NOTICE UNDER THE TURKISH PERSONAL DATA PROTECTION LAW (KVKK)
Last updated:
31.08.2026
This notice has been prepared by YATPAZARI A.Ş. (the "Company") in its capacity as data controller, pursuant to Article 10 of Turkish Law No. 6698 on the Protection of Personal Data ("KVKK") and the Communiqué on the Procedures and Principles for Fulfilling the Disclosure Obligation. The Company operates the website www.azzurro.com.tr (the "Site") under the AZZURRO MARINE brand.
Data controller
YATPAZARI A.Ş.
Registered address
Yalıpark AVM, Bodrum Cd. No:1, 48990 Yalıkavak, Bodrum / Muğla, Türkiye
MERSIS No
0940107451800001
Application e-mail
info@azzurro.com.tr
2.1 Site visitors
Category
Examples
Transaction security
IP address, browser and device information, operating system, date and time of visit, pages viewed, referring URL, cookie identifiers
Marketing
Usage and conversion data obtained via advertising and measurement cookies (only where consent is given)
2.2 Contact form submissions
Category
Examples
Identity
First name, surname
Contact
E-mail address, phone number
Customer transaction
Selected department, message content and any information included in it
Please note: kindly do not include special categories of personal data (health, religion, membership etc.) or images of identity documents in the free-text message field.
2.3 Newsletter subscribers
Category
Examples
Contact
E-mail address
Marketing
Subscription date, consent record, open and click data relating to messages sent
2.4 Career applicants (via the "Career Opportunities" option in the contact form)
Category
Examples
Identity / Contact
First name, surname, e-mail, phone
Professional experience
Education, work history and skills disclosed in the CV
2.5 Pre-owned yacht owners / sellers and their representatives
Category
Examples
Identity / Contact
First name, surname, e-mail, phone
Customer transaction
Information declared about the yacht, listing process correspondence
2.6 Partnership and dealership applicants
Category
Examples
Identity / Contact
Name, represented company, e-mail, phone
Customer transaction
Application content and correspondence
Operating, securing and troubleshooting the Site
Receiving and responding to contact, information and quotation requests
Conducting buyer–seller communication and brokerage services for pre-owned yacht listings
Presenting products and services of the brands we distribute
Managing after-sales support, technical service and maintenance requests
Where consent has been given, sending newsletters, boat show announcements and campaign messages
Assessing partnership and dealership applications
Assessing job applications and managing human resources processes
Fulfilling legal obligations and responding to requests from competent public authorities
Exercising the right of defence in the event of a dispute
Where consent has been given, analysing user behaviour and measuring advertising performance via marketing and measurement cookies
4. Method of Collection
Personal data is collected wholly or partly by automated means in electronic form, through the contact and newsletter forms on the Site, e-mail, telephone, WhatsApp, social media channels, boat show and event contacts, cookies and similar tracking technologies, and server logs.
5. Legal Grounds for Processing
Processing activity
Legal ground (KVKK Art. 5)
Operation of the Site, server logs, strictly necessary cookies
Art. 5/2-f — legitimate interest; Art. 5/2-ç — legal obligation
Responding to contact and quotation requests
Art. 5/2-c — directly related to the conclusion/performance of a contract; Art. 5/2-f
Pre-owned listing and brokerage processes
Art. 5/2-c — conclusion/performance of a contract
Newsletters and commercial electronic messages
Art. 5/1 — explicit consent (plus consent and İYS registration under Law No. 6563)
Advertising / measurement cookies
Art. 5/1 — explicit consent
Assessment of job applications
Art. 5/2-c and 5/2-f; retention in a talent pool requires explicit consent
Statutory retention and reporting obligations
Art. 5/2-ç — legal obligation
Defence in disputes
Art. 5/2-e — establishment, exercise or protection of a right
6. Transfers of Personal Data
6.1 Domestic transfers
Limited to the purposes above, your personal data may be transferred under Article 8 of the KVKK to:
our IT, hosting, e-mail and infrastructure service providers,
our accountants, independent auditors and legal advisers,
where relevant, the counterparty to a pre-owned transaction (buyer or yacht owner) and to survey, insurance and transport service providers involved in the process,
competent public authorities upon request.
6.2 International transfers
The Site is hosted on Framer B.V./Framer Inc. infrastructure. We also use service providers established abroad, including Google (Google Tag Manager and Google Ads) and, where used, e-mail delivery providers. Data may also be shared with our office in Olbia, Italy for operational purposes. Your personal data is therefore transferred abroad.
Transfers abroad are carried out under Article 9 of the KVKK, in the following order:
on the basis of an adequacy decision issued by the Turkish Personal Data Protection Board for the relevant country, sector or international organisation;
where no adequacy decision exists, on the basis of one of the appropriate safeguards listed in Article 9(3) (standard contract, binding corporate rules, undertaking, etc.);
where neither is available, on an incidental basis, relying on the exceptions in Article 9(6) or on the data subject's explicit consent.
Transfers relating to advertising and measurement cookies occur only if you select "Accept" on the cookie banner.
7. Retention Periods
Data
Retention period
Contact form records
3 years from resolution of the request
Records relating to pre-owned listings and brokerage
10 years from the end of the relationship (limitation period, TCO Art. 146)
Records subject to commercial bookkeeping
10 years (TCC Art. 82; 5 years under Tax Procedure Law Art. 253)
Newsletter subscription and consent records
3 years from the end of the subscription; consent records 1 year from withdrawal (Law No. 6563)
Server / traffic logs
2 years (obligation period under Law No. 5651)
Cookie data
As stated in the Cookie Policy
Job applications and CVs
1 year from conclusion of the application (talent-pool retention subject to explicit consent)
At the end of the retention period, personal data is deleted, destroyed or anonymised.
8. Your Rights as a Data Subject (KVKK Art. 11)
You have the right to:
learn whether your personal data is being processed,
request information if it has been processed,
learn the purpose of processing and whether the data is used in accordance with that purpose,
know the third parties to whom the data has been transferred, in Türkiye or abroad,
request correction of incomplete or inaccurate data,
request deletion or destruction under the conditions set out in Article 7,
request that correction, deletion and destruction be notified to third parties to whom the data has been transferred,
object to any adverse outcome resulting exclusively from automated analysis,
claim compensation for damage suffered due to unlawful processing.
9. How to Submit a Request
You may submit your requests in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, by:
E-mail: info@azzurro.com.tr (where sent from the e-mail address previously notified to us and registered in our systems)
Written application: a signed petition delivered in person or through a notary — Yalıpark AVM, Bodrum Cd. No:1, 48990 Yalıkavak, Bodrum / Muğla, Türkiye
Your application should state your name and surname, signature, Turkish ID number (passport number for foreign nationals), address for service, e-mail/phone if any, and the subject of your request.
We will respond within 30 days at the latest. Where the request requires additional cost, a fee may be charged in accordance with the tariff set by the Board.
If your application is rejected, the response is found insufficient, or no response is given in time, you may lodge a complaint with the Personal Data Protection Board within 30 days of learning the response and in any event within 60 days of the date of application.
10. Amendments
This notice may be revised in line with legislative changes or updates to our processing activities. The current version is always published on the Site.