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POLICIES

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PRIVACY POLICY

PRIVACY POLICY

Last updated:

31.08.2026

1. Introduction

YATPAZARI A.Ş. (the "Company", "we") respects the privacy of visitors to www.azzurro.com.tr (the "Site"), which it operates under the AZZURRO MARINE brand.

This Privacy Policy explains what data we collect through the Site, why and how we use it, who we share it with, and how you can exercise your rights.

For persons resident in Türkiye, detailed information under Law No. 6698 is set out in the KVKK Privacy Notice; details on cookies are set out in the Cookie Policy. These three documents should be read together.

2. Data We Collect

Data you provide directly

  • Contact form: name, surname, e-mail, phone, selected department, message content

  • Newsletter subscription: e-mail address

  • Career applications: information disclosed in your CV

  • The content of correspondence with us by e-mail, phone or social media

Data collected automatically

  • IP address, browser and device information, operating system, language preference

  • Date and time of visit, pages viewed, time on site, referring URL

  • Identifiers and usage data obtained through cookies and similar technologies

Data we do not collect

  • No payment is taken through the Site, so no credit card, bank account or payment instrument data is collected.

  • There is no membership system, so no username or password data is collected.

3. Why We Use Your Data

To operate, secure and improve the Site

  • To respond to your requests, questions and quotation enquiries

  • To conduct brokerage processes relating to pre-owned yacht listings

  • To provide information about the brands we distribute

  • To send newsletters, boat show announcements and campaign messages where you have consented

  • To assess partnership applications and job applications

  • To comply with our legal obligations and to exercise our right of defence against legal claims

  • To measure advertising performance and analyse usage where you have consented

4. Who We Share Data With

We do not sell, rent or transfer your data to third parties for marketing purposes. Sharing occurs only in the following cases:

Recipient

Purpose

Hosting and site infrastructure provider (Framer)

Publication and technical operation of the Site

Google (Google Tag Manager, Google Ads)

Advertising measurement and conversion tracking — only with your consent

E-mail and newsletter delivery provider

Sending newsletters and informational messages

Accountants, auditors and legal advisers

Fulfilment of financial and legal obligations

Counterparty and service providers involved in a transaction (survey, insurance, transport)

Execution of a pre-owned yacht transaction

Competent public authorities

Statutory obligations

Sharing with group companies or our office in Olbia, Italy takes place only where operationally necessary and within the limits of this Policy.

5. International Data Transfers

Some of our service providers host their servers outside Türkiye, so your data may be transferred abroad.

  • Under Turkish law: transfers are made under Article 9 of the KVKK, relying on an adequacy decision, appropriate safeguards (standard contract, undertaking, etc.) or the statutory exceptions.

  • Under EU law: transfers from the EU/EEA are made in accordance with Articles 44–49 GDPR, relying on an adequacy decision or the European Commission's Standard Contractual Clauses together with supplementary measures.

6. Data Security

We apply administrative and technical measures to protect your personal data against unauthorised access, loss and disclosure: HTTPS/TLS encryption, access authorisation and role-based restrictions, use of up-to-date infrastructure, data processing agreements with suppliers, and confidentiality undertakings for staff.

Please note that no transmission over the internet can be guaranteed to be 100% secure. We therefore recommend that you do not upload sensitive documents (identity documents, tonnage certificates, financial records) into the free-text message field on the Site.

7. Retention

We retain your data for as long as necessary for the purpose of collection and for the mandatory retention periods set out in applicable legislation. For detailed retention periods, see clause 7 of the KVKK Privacy Notice.

8. Children's Data

The Site is not directed at persons under 18 and we do not knowingly collect personal data from children. If we become aware that we have collected such data, we will delete it without delay. Please contact info@azzurro.com.tr if you believe this has occurred.

9. Commercial Electronic Messages

Newsletter subscription is entirely optional and takes place only with your consent. Your consent is recorded in accordance with Turkish Law No. 6563 on the Regulation of Electronic Commerce and uploaded to the Message Management System (İYS).

You may unsubscribe at any time, without giving a reason and free of charge, by:

  • using the unsubscribe link at the bottom of every message we send,

  • through İYS (iys.org.tr),

  • or by e-mailing info@azzurro.com.tr.

Your request will be actioned within 3 business days at the latest.

10. Your Rights

If you are resident in Türkiye: see clauses 8 and 9 of the KVKK Privacy Notice for your rights under Article 11 KVKK and the application procedure.

If you are resident in the EU/EEA: section 11 below applies.

11. Additional Information for Individuals in the European Union (GDPR)

This section applies where the EU General Data Protection Regulation (GDPR — 2016/679) applies.

11.1 Controller

YATPAZARI A.Ş., Yalıpark AVM, Bodrum Cd. No:1, 48990 Yalıkavak, Bodrum / Muğla, Türkiye — info@azzurro.com.tr

11.2 Legal bases for processing

Activity

Legal basis (Art. 6 GDPR)

Responding to requests and enquiries, pre-contractual discussions

Art. 6(1)(b) — performance of a contract / pre-contractual steps

Site security, prevention of misuse, core functionality

Art. 6(1)(f) — legitimate interests

Newsletters and marketing messages

Art. 6(1)(a) — consent

Advertising and analytics cookies

Art. 6(1)(a) — consent (Art. 5(3) ePrivacy Directive)

Statutory retention and reporting obligations

Art. 6(1)(c) — legal obligation

Establishment, exercise or defence of legal claims

Art. 6(1)(f) — legitimate interests

To exercise your rights, write to info@azzurro.com.tr. We will respond within one month as a rule; this period may be extended by a further two months depending on the complexity of the request, in which case we will inform you.

11.4 Automated decision-making

We do not carry out decision-making based solely on automated processing, or profiling, which produces legal effects concerning you or similarly significantly affects you.

11.5 Transfers to third countries

The Company is established in Türkiye. Transfers from the EU/EEA to Türkiye and other third countries are based on the European Commission's Standard Contractual Clauses (SCCs) together with any necessary supplementary measures. You may request a copy of the safeguards applied.

11.6 Obligation to provide data

Providing the data requested in our forms is neither a statutory nor a contractual requirement; however, without it we may be unable to respond to your request.

12. Linked Sites

The Site may contain links to third-party websites and social media platforms. This Policy applies only to www.azzurro.com.tr; we recommend that you review the privacy notices of any other sites you visit.

13. Amendments

This Policy may be updated from time to time. Material changes will be announced on the Site. The date of the version in force is shown at the top of this page.

14. Contact

E-mail: info@azzurro.com.tr Phone: +90 (553) 844 44 44 Address: Yalıpark AVM, Bodrum Cd. No:1, 48990 Yalıkavak, Bodrum / Muğla, Türkiye