PERSONAL DATA PROTECTION

INFORMATION NOTICE

(Pursuant to Article 10 of the Turkish Law No. 6698 – KVKK)


1. Purpose and Scope

This Personal Data Protection Information Notice (“Information Notice”) has been prepared by MUSTER STATION ERP BUSINESS CORP. (“Company” or “DenizKariyer”), acting as the data controller, in accordance with:

  • Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”),

  • secondary legislation issued under KVKK,

  • decisions of the Turkish Personal Data Protection Authority,

  • and internationally recognized data protection and privacy principles,

for the purpose of fulfilling the obligation to inform data subjects regarding the processing of personal data within the scope of the Platform.


2. Identity of the Data Controller

Data Controller:
DENIZ KARIYER BUSINESS CORP.

Place of Incorporation: Republic of the Marshall Islands
Registered Address:
Trust Company Complex, Ajeltake Road,
Ajeltake Island, Majuro, MH96960
Marshall Islands

Contact (Data Protection & KVKK):
[email protected]

Note:
Although the Company is incorporated outside Türkiye, it undertakes to comply with the provisions of KVKK with respect to personal data of data subjects residing in Türkiye.


3. Categories of Personal Data Processed

The following categories of personal data may be processed within the scope of the Platform:

a) Identity and Contact Data

  • Name and surname

  • Date of birth

  • Email address

  • Phone number

b) Membership and Account Data

  • User account information

  • Membership status and preferences

  • Profile photo (if uploaded)

c) Professional and CV Data

  • Education information

  • Professional experience

  • Certificates and qualifications

  • Reference information (if provided)

d) Maritime-Specific Data

  • Seafarer’s book information

  • Passport and visa details

  • Professional competency and compliance documents

e) Transaction Security and Technical Data

  • IP address

  • Log records

  • Device, browser, and session data

  • Authentication and security records

f) Special Categories of Personal Data

(processed only with explicit consent)

  • Health data

  • Blood group

  • Medical reports and certificates

  • Biometric data (if uploaded)


4. Purposes of Processing Personal Data

Personal data are processed for the following purposes:

  • Creating and managing Platform memberships

  • Conducting job search, application, and candidate–employer matching processes

  • Creating, updating, and displaying profiles and CVs

  • Establishing and performing Platform-related contracts

  • Managing user support, requests, and complaints

  • Ensuring Platform security

  • Detecting fraud, abuse, and suspicious activities

  • Conducting information security, logging, and audit activities

  • Improving service quality and system performance

  • Fulfilling legal obligations

  • Communicating with authorized public authorities


5. Method of Collection of Personal Data

Personal data are collected entirely by electronic means through:

  • Membership, application, and profile forms on the Platform

  • Automatically generated records during Platform use

  • Cookies and similar technologies

  • Emails, contact forms, and support channels


6. Legal Grounds for Processing Personal Data

Personal data are processed based on the legal grounds set forth in Articles 5 and 6 of KVKK, including:

  • KVKK Art. 5/2(c): Necessity for the establishment or performance of a contract

  • KVKK Art. 5/2(ç): Compliance with legal obligations

  • KVKK Art. 5/2(e): Establishment, exercise, or protection of a legal right

  • KVKK Art. 5/2(f): Legitimate interests of the Company (e.g., Platform security, abuse prevention)

  • KVKK Art. 5/1: Explicit consent (where required)

  • KVKK Art. 6: Special categories of personal data (processed with explicit consent)


7. Transfer of Personal Data

Personal data may be transferred, limited to the purposes stated above and in accordance with applicable legislation, to:

  • Employers registered on the Platform

  • Companies operating in the maritime sector

  • Authorized public institutions and authorities

  • Legal, financial, and technical service providers
    (hosting, infrastructure, email, SMS, security, and support services)

International Data Transfers

Personal data may be transferred abroad pursuant to Article 9 of KVKK, provided that:

  • the data subject’s explicit consent is obtained, and/or

  • other legal transfer conditions stipulated by applicable legislation are satisfied.


8. Retention Period

Personal data are retained:

  • for the period required by the purposes of processing, and

  • in accordance with statutory limitation and retention periods prescribed by applicable legislation.

Upon expiration of such periods, personal data are deleted, destroyed, or anonymized.


9. Rights of the Data Subject (KVKK Art. 11)

Pursuant to Article 11 of KVKK, data subjects have the right to:

  • Learn whether personal data are processed

  • Request information if personal data have been processed

  • Learn the purpose of processing and whether data are used in accordance with such purpose

  • Know third parties to whom data are transferred domestically or abroad

  • Request correction of incomplete or inaccurate data

  • Request deletion, destruction, or anonymization under legal conditions

  • Object to adverse outcomes resulting from automated processing

  • Claim compensation for damages arising from unlawful processing

Requests may be submitted together with identity verification documents to:
[email protected]

Applications will be evaluated and concluded within the time limits stipulated by KVKK.


10. Amendments

The Company reserves the right to update this Information Notice in line with legislative changes, regulatory authority decisions, or operational requirements.
The updated version shall enter into force upon publication on the Platform.