MACREWMANAGEMENT.COM PRIVACY POLICY AND CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA

Last Updated: July 24, 2025

This Privacy Policy and Clarification Text sets out the procedures and principles for the processing of personal data of our users (“User”, “Candidate” or “Data Subject”) who visit our website located at www.macrewmanagement.com (“Site”), create a membership, or share their personal data with us by applying for a job through our site, by MA Crew Management (“macrewmanagement.com” or “Company”), in accordance with the Law on Protection of Personal Data No. 6698 (“KVKK”) and other relevant legislation.

The security of your data is of utmost importance to us. Therefore, all personal data you share with our Company is processed lawfully, in connection with and proportionate to our activity and service purposes, and its confidentiality and security are ensured.

1. Identity of the Data Controller

In accordance with the KVKK, your personal data may be processed by MA CREW MANAGEMENT as the data controller within the scope explained below.

Company Title: MA CREW MANAGEMENT
Tax Office and Number: [Please replace with current tax information]
Address: [Please enter the company's legal address]
Phone: +90 [Phone number]
Email: info@macrewmanagement.com

2. Purposes of Processing Personal Data

Your personal data collected through our Site and directly by us is processed for the following purposes and limited to these purposes:

Execution of Personnel Recruitment Processes:
- To receive, evaluate, and manage your job applications.
- To match candidates' qualifications, experience, and skills with job position requirements.
- To communicate with candidates, organize interviews, and conduct reference checks.
- To process candidate CVs, videos, and other application documents and evaluate them for relevant positions.
- To recommend suitable candidates to shipping companies and to act as a bridge between these companies and candidates.

Fulfillment of Contractual Obligations:
- To establish and perform potential service agreements with candidates.
- To fulfill the requirements of agreements made with the shipping companies we serve.

Execution of Financial and Accounting Transactions:
- To process your payments and issue invoices (where applicable, e.g., for service purchases).
- To ensure financial reconciliation and keep accounting records.

Fulfillment of Legal Obligations:
- To retain traffic information (log records) in accordance with Law No. 5651 on Regulating Publications Made on the Internet and Fighting Crimes Committed Through These Publications.
- To keep accounting records and other mandatory records as required by relevant legal legislation.
- To respond to requests from authorized public institutions and organizations.

Communication and Customer Relationship Management:
- To respond to your questions, requests, and feedback.
- To make announcements regarding our services.

Ensuring Security:
- To ensure the security of our Site and information systems.
- To prevent and detect fraud.
- To ensure the security of user accounts.

3. Categories of Personal Data Processed and Their Legal Grounds

As MA Crew Management, within the scope of the services we provide, we process the personal data categories listed below, based on the legal grounds specified in Articles 5 and 6 of the Law on Protection of Personal Data No. 6698 (“KVKK”):

Identity Information: Name, surname, TR ID number, date of birth, place of birth, gender, marital status, passport information, nationality.
Legal Ground: Being directly related to the establishment or performance of a contract (KVKK Art. 5/2-c); fulfillment of a legal obligation (KVKK Art. 5/2-ç); legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject (KVKK Art. 5/2-f).

Contact Information: Phone number, email address, residential address, mobile phone number.
Legal Ground: Establishment and performance of the contract (KVKK Art. 5/2-c); legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject (KVKK Art. 5/2-f).

Education and Professional Experience Information: Education status (graduation information, schools), professional experience, previous employers, positions, certificates, courses, foreign language knowledge, driving license information.
Legal Ground: Legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject (KVKK Art. 5/2-f) (Especially for recruitment and candidate pool creation processes); explicit consent (KVKK Art. 5/1) (Especially for detailed CV sharing).

Visual and Audio Recordings: Videos shared by candidates as part of their job application (if any).
Legal Ground: Explicit consent (KVKK Art. 5/1).

Financial Information: Bank account details (only when necessary, e.g., during payment processes after service acquisition).
Legal Ground: Establishment, exercise, or protection of a right (KVKK Art. 5/2-e); fulfillment of a legal obligation (KVKK Art. 5/2-ç).

Transaction Security Data: IP address, log records, session information, user actions (during Site use).
Legal Ground: Legitimate interests of the data controller (KVKK Art. 5/2-f); fulfillment of legal obligations (KVKK Art. 5/2-ç) (as per Law No. 5651).

Health Information and Criminal Conviction/Security Measures (Special Categories of Personal Data): Health reports (e.g., medical fitness certificates for sea service), criminal records (judicial record certificate) that may be obtained with the explicit consent of the candidate, especially for positions in the maritime sector due to legal requirements or requests from shipping companies.
Legal Ground: Explicit consent (KVKK Art. 6/2); for the protection of public health, preventive medicine, medical diagnosis, treatment and care services, the planning and management of health services and their financing, by persons or authorized institutions and organizations under the obligation of secrecy (KVKK Art. 6/3) (for health data).

All personal data is processed in a limited, connected, and proportionate manner to the processing purposes; and is protected in accordance with the KVKK and relevant legislation.

4. Transfer of Personal Data

Your personal data may be transferred to third parties located domestically and/or abroad, in line with the purposes mentioned above and within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK, by taking the necessary security measures:

Service Providers and Business Partners: Payment service providers (if any), technology companies providing software and infrastructure services, outsourced consultancy firms.
Shipping Companies/Firms: As part of the candidate application processes, CVs, videos, and other relevant personal data of candidates may be transferred by us to the shipping companies we serve for evaluation for suitable positions. This transfer occurs in connection with the candidate applying for a job with our Company and/or agreeing to be included in our candidate pool.
Authorized Public Institutions and Organizations: Administrative and judicial authorities such as courts, public prosecutors' offices, and ministries, if requested due to legal obligations.

5. Retention Period of Personal Data

Your personal data will be kept for the retention periods stipulated in the relevant legislation or for the maximum period necessary for the purpose for which they are processed. Specifically:
- Data of candidates whose job application has been rejected or whose process has been completed may be stored for periods permitted by relevant legislation (e.g., 2 years) for possible legal obligations and for re-evaluation for similar positions that may arise in the future.
- Data of individuals with whom a service contract relationship has been established will be kept for the duration of the contract and after the termination of the contract for legal retention periods (e.g., Tax Procedure Law, Turkish Commercial Code, etc.).
- Log records kept due to legal obligations will be stored for the period specified in Law No. 5651.

Upon expiration of the period or disappearance of the processing purpose, your personal data will be deleted, destroyed, or anonymized ex officio or upon your request, in accordance with Article 7 of the KVKK.

6. Rights of the Data Subject (KVKK Article 11)

As a personal data owner, you have the following rights under Article 11 of the KVKK:
- To learn whether your personal data is being processed,
- To request information if your personal data has been processed,
- To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
- To know the third parties to whom your personal data has been transferred domestically or abroad,
- To request the correction of your personal data if it is incomplete or incorrectly processed,
- To request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the KVKK,
- To request that the transactions made pursuant to subparagraphs (d) and (e) be notified to third parties to whom your personal data has been transferred,
- To object to the emergence of a result against you by analyzing your processed data exclusively through automated systems,
- To request compensation for damages in case you suffer damage due to unlawful processing of your personal data.

To exercise these rights, you can submit your application, along with documents proving your identity, in writing to our address specified above or by using your electronic mail address previously notified to us and registered in our system, to info@macrewmanagement.com. Your applications will be concluded free of charge as soon as possible and within 30 (thirty) days at the latest, depending on their nature.

7. Cookie Policy

As Macrewmanagement.com, we use cookies to ensure that our site works more efficiently, to personalize and improve the user experience. You can change your cookie preferences at any time through your browser settings. For more detailed information, please review our Cookie Policy.

8. Data Security

Our Company takes SSL certificate usage, data encryption, access controls, and other current technical and administrative measures to prevent unlawful processing and access to your personal data and to ensure the preservation of data. Especially in the processing of your sensitive data (such as health information), special security measures determined by KVKK are meticulously applied.

9. Changes to the Policy

Macrewmanagement.com reserves the right to make changes to this Privacy Policy and Clarification Text due to legal regulations and Company policies. The changes made become effective as of the date they are published on the Site.

10. Retention Period

"The data of candidates whose applications are unsuccessful will be retained for a maximum of 2 years for use in future evaluations. After this period, the data will be anonymized or deleted."