This text is a draft. Have it reviewed by your legal adviser before publishing and fill in the bracketed fields. In case of conflict, the Turkish version prevails.
1. Data controller
Your personal data is processed by RAFMARIN ("Rafmarin") as data controller under KVKK. Address: Tuzla / Istanbul. E-mail: info@rafmarin.com.
2. Personal data we process
The following categories may be processed through our website and services:
- Identity and contact: full name, phone number, e-mail address
- Boat details: make/model, length, weight, type, equipment (T-top/tower), current location
- Request details: package of interest, message content
- Contract and finance: invoicing details, payment records (if a service is purchased)
- Visual records: photo-documented check-in/check-out reports, 24/7 CCTV recordings (during facility visits)
- Technical data: IP address, browser information, cookie/local storage data (see Cookie Policy)
3. Purposes of processing
- Evaluating your quote request, assigning a rack class and sending you a written quote
- Communicating with you (phone, e-mail, WhatsApp)
- Concluding and performing the service contract; scheduling haul-out / launch movements
- Ensuring facility security and documenting condition (photo reports, CCTV)
- Invoicing, accounting and compliance with legal obligations
- Marketing and information communications, where you have given explicit consent
4. Legal basis
Data is processed under KVKK art. 5/2: (c) conclusion or performance of a contract, (ç) compliance with a legal obligation, (e) establishment, exercise or protection of a right, and (f) our legitimate interests; where none applies (e.g. marketing), on the basis of your explicit consent.
5. Transfers
Limited to the purposes above, data may be transferred to:
- Hosting: the website is hosted on Amazon Web Services (AWS) in the European Union region (Frankfurt, Germany); no personal data is stored on the site itself.
- Form infrastructure: quote form submissions are delivered to our inbox through our own form service, also running on AWS (Frankfurt, Germany); data is not shared with any third-party form provider. As AWS servers are located abroad, this constitutes a transfer abroad under KVKK art. 9, based on your explicit consent.
- Partner insurance agency: only at your request, for insurance advisory
- Public authorities: upon lawful request
- Service providers: accounting, hosting and IT suppliers
6. Retention
Quote requests are kept for [12 months] if no contract is concluded; otherwise for the contract term and the statutory limitation period thereafter (10 years). CCTV recordings are deleted after [30 days].
7. Your rights under KVKK art. 11
- To learn whether your personal data is processed and to request information
- To learn the purpose of processing and whether data is used accordingly
- To know the third parties to whom data is transferred, in Türkiye or abroad
- To request correction of incomplete or inaccurate data
- To request erasure or destruction under KVKK art. 7
- To request that corrections/erasures be notified to recipients
- To object to results arising from automated analysis to your detriment
- To claim compensation for damage caused by unlawful processing
8. How to submit a request
Send your request with proof of identity by e-mail to info@rafmarin.com or in writing to our Tuzla / Istanbul address. Requests are answered free of charge within 30 days.