DESE CREW MANAGEMENT MARINE LOGISTICS SERVICES INDUSTRY

TRADE LIMITED COMPANY

CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA

SECTION 1 - INTRODUCTION

This Clarification Text has been prepared by DESE Crew Management Denizcilik Lojistik Hizmetleri Sanayi Ticaret Limited Şirketi (“”Company“”) in order to enlighten the Company's customers regarding the processing of their personal data by the Company within the scope of the Personal Data Protection Law No. 6698 (“Law”).

Detailed information on the processing of your personal data within the scope of this Clarification Text can be found in the DESE Crew Management Denizcilik Lojistik Hizmetleri Sanayi Ticaret Limited Şirketi Personal Data Protection and Processing Policy at [www.desecrew.com].

This Clarification Text includes the methods of obtaining personal data and their legal reasons, the purposes of processing, the rights of personal data owners, and the ways to exercise these rights.

SECTION 2 - ISSUES RELATED TO THE PROCESSING OF PERSONAL DATA

Your personal data is collected electronically or physically. Your personal data collected for the legal reasons specified in this Clarification Text may be processed and shared within the framework of the personal data processing conditions specified in Articles 5 and 6 of the Law.

Your personal data is processed for the following purposes:

•        Planning and/or execution of our Company's human resources policies and processes,

•        Planning and/or execution of activities to ensure the legal and technical security of our Company and related persons who are in business relations with our Company,

•        Planning and/or execution of the activities necessary for the recommendation and promotion of the products and services offered by and/or on behalf and account of our Company to the relevant persons by customizing them according to the tastes, usage habits and needs of the relevant persons,

•        Carrying out the necessary work and carrying out the relevant business processes in order to benefit the relevant persons from the products and/or services offered by and/or on behalf and account of our Company,

•        Carrying out the necessary work by our relevant business units for the realization of the commercial and/or operational activities carried out by our Company and carrying out the related business processes,

•        It is processed for the purposes of planning and/or execution of our Company's commercial and/or business strategies.

•        Your name, surname, occupation, address, telephone and fax numbers, e-mail address and other contact information,

•        Your family and demographic information,

•        Your identity and passport details,  Your travel and route information,

•        Your ticketing and booking details,

•        Your information on invoicing and payment instruments,

•        Your camera/video/photo records collected for security purposes,

•        Your health data collected to fulfill our legal responsibilities regarding accidents,

•        Your details for making payments and receiving refunds,

•        Your information that you have communicated to our employees within the scope of your requests and complaints regarding products and services,

•        Your information regarding your use of our website and other communication channels,

•        For users of our website, other information arising from your visit to our website, use of our services, interaction with our content and advertisements, including computer/hardware and connection information, page view statistics, traffic information to and from the page, ad data/advertising data, IP addresses and standard web log information/standard web log information;

•        This information is collected to the extent permitted and within the limits permitted by the relevant legislation and the agreements made through the channels through which organizations and persons authorized to represent such as the website, mobile or digital applications, social media, companies whose activities we carry out in the capacity of intermediary/agency, customer interviews, SMS, written/digital applications made to other websites, support service organizations, including those from which services are received, contact you or may contact you in the future, by obtaining your consent where legally mandatory.

2.4 Your personal data collected by these methods may also be processed and transferred for the purposes specified in Articles 2.3 of this Information within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.

Your personal data may be shared with the Company's business partners and suppliers, legally authorized institutions and organizations and legally authorized private legal entities within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law, for the purposes of carrying out the necessary work by the relevant business units for the realization of the commercial activities carried out by the

Company and the execution of the related business processes, planning and execution of the Company's commercial and / or business strategies and ensuring the legal, technical and commercial-business security of the Company and the relevant persons who have a business relationship with the Company.

As personal data owners, if your requests regarding your rights specified below are submitted to the Company by the methods specified under the heading of Exercise of Rights by Data Owners, your requests will be evaluated and finalized by our Company as soon as possible and in any case within 30 (thirty) days.

Personal data subjects have the following rights pursuant to Article 11 of the Law:

•        Learn whether personal data is being processed,

•        Request information if their personal data has been processed,

•        To learn the purpose of processing personal data and whether they are used for their intended purpose,

•        To know the third parties to whom 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 within the framework of the conditions stipulated in Article 7 of the Law,

•        In case of incomplete or incorrect processing of personal data and to request notification to third parties to whom personal data has been transferred for actions to be taken regarding the deletion or destruction of personal data,

•        By analyzing the processed data exclusively through automated systems objecting to a result that is unfavorable to oneself,

•        In the event that personal data is damaged due to unlawful processing of personal data, it has the right to demand the compensation of the damage.

Pursuant to the provision of paragraph 2 of Article 28 of the Law, the situations where the data subject has no right to request are listed below:

•        Processing of personal data is necessary for the prevention of crime or criminal investigation,

•        Processing of personal data made public by the data subject himself/herself,

•        Personal data processing is necessary for the execution of supervisory or regulatory duties and disciplinary investigation or prosecution by the authorized and authorized public institutions and organizations and professional organizations in the nature of public institutions based on the authority granted by law,

•        In cases where personal data processing is necessary for the protection of the economic and financial interests of the State in relation to budget, tax and financial matters, the above-mentioned rights will not be exercised in relation to the data.

According to paragraph 1 of Article 28 of the Law, in the following cases, since the data will be outside the scope of the Law, the requests of the data subjects will not be processed in terms of these data:

•        Personal data are processed by natural persons within the scope of activities related to themselves or their family members living in the same residence, provided that they are not disclosed to third parties and data security obligations are complied with.

•        Processing of personal data for purposes such as research, planning and statistics by anonymizing them with official statistics.

•        Processing of personal data for the purposes of national defense, national security, public security, public safety, public order, economic security, confidentiality of private life or personal rights or for the prevention of criminal offenses. for artistic, historical, literary or scientific purposes or within the scope of freedom of expression, provided that such processing does not constitute a violation of freedom of expression.

•        Processing of personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations authorized by law to ensure national defense, national security, public security, public order or economic security.

•        Processing of personal data by judicial authorities or enforcement authorities in relation to investigation, prosecution, trial or execution proceedings.

Data subjects may exercise the aforementioned rights by contacting [www.desecrew.com]

They will be able to use the “Form for Applications to be made by the Personal Data Owner to the Data Controller” available at the link.

•        Applications shall be made by one of the following methods together with the documents that will identify the identity of the relevant data subject:

•        The form should be completed and a wet signed copy sent by hand, through a notary public or by registered letter with return receipt [Adalet Mah. Manas Bulv. No:4 B K:26 D:2601 Folkart Towers A Tower Bayraklı/İzmir/Turkey] to the address below,  Following a method stipulated by the Personal Data Protection Board.

•        The Company responds to data subjects who wish to exercise such rights within the limits stipulated in the Law within a maximum period of thirty (30) days as stipulated in the Law. In order for third parties to make an application request on behalf of personal data subjects, there must be a special power of attorney issued by the data subject through a notary public on behalf of the person who will make the application.

•        Although data subject applications are processed free of charge as a rule, if necessary, charges may be made over the fee tariff stipulated by the Personal Data Protection Board.

•        The Company may request information from the relevant person in order to determine whether the applicant is a personal data owner or not, and may ask questions to the personal data owner about his/her application in order to clarify the matters specified in the application.