Privacy Policy

This Privacy Policy explains how your personal data is collected, processed, stored, shared, and protected when you visit marinabelous.com or use our services. The Policy is prepared in accordance with the Republic of Turkey’s Law No. 6698 on the Protection of Personal Data (KVKK) and relevant legislation, and it complements the Personal Data Processing Notice (Aydınlatma Metni).

1. Definitions
Personal Data: Any information relating to an identified or identifiable natural person.
Special Categories of Personal Data: Sensitive data as specified in Article 6 of KVKK.
Data Controller: ATİLLA ALP MARANGOZOĞLU.

2. Data Controller Information
Data Controller: ATİLLA ALP MARANGOZOĞLU (Sole Proprietorship)
Address: Gayrettepe Mah. Ayazmaderesi Cad., Şener Apt. NO:9/5, Beşiktaş, İstanbul, Türkiye
E-mail: info@marinabelous.com
Telephone: +90 542 464 5514
Tax Identification Number (VKN): 6120145416
Under KVKK, the appointment of a Data Protection Officer (DPO) is not mandatory. For requests, please contact info@marinabelous.com.

3. Collected Personal Data and Collection Methods
The following data may be collected in connection with our services:
• Identity Information: Name, surname, Turkish ID number (only for legal obligations, e.g., invoicing; KVKK Art. 5/2-ç).
• Contact Information: Telephone number, e-mail address, postal address (for service provision and communication; KVKK Art. 5/2-c).
• Payment and Invoicing Information: Payment method details (credit card information is not stored and is processed solely by payment providers), invoicing details (for legal obligations; KVKK Art. 5/2-ç).
• Reservation and Order Information: Records of events, workshops, sessions, order numbers (for contract performance; KVKK Art. 5/2-c).
• Content Information: Contact forms, messages, feedback (for managing requests and complaints; KVKK Art. 5/2-f).
• Technical Information: IP address, browser and device information, cookies, log records (for website security and improvement; KVKK Art. 5/2-f).
• Special Categories of Data: Processed only with your explicit consent, except in cases covered by Art. 6/3 of KVKK (e.g., public health protection or processing by persons under confidentiality obligations). Outside these exceptions, explicit consent is required (KVKK Art. 6/2). Special categories of data are processed with additional security measures as stipulated in Art. 12 of KVKK.
• Note: Data of individuals under 18 is processed only with the consent of their legal representatives.
Data is collected through registration forms, cookies, payment systems, or third parties (e.g., payment providers).

4. Purposes and Legal Bases for Processing Personal Data
Your data is processed for the following purposes (KVKK Arts. 5 and 6):
• Execution of service contracts (reservations, payments, event organization; Art. 5/2-c).
• Compliance with legal obligations (tax, invoicing; Art. 5/2-ç).
• Our legitimate interests (website security, service improvement; Art. 5/2-f).
• Your explicit consent (marketing, special categories of data; Art. 5/1).

5. Transfer of Personal Data and International Transfers
Your data may be transferred in accordance with KVKK Arts. 8 and 9 to the following parties:
Within Türkiye: Payment institutions, IT service providers, courier companies, public authorities.
International Transfers: For international transfers, the list of “countries with adequate protection” published by the Personal Data Protection Board (Kurul) is taken into account. In cases where adequate protection is not available, your explicit consent is obtained, or contractual safeguards (e.g., standard contractual clauses, binding corporate rules) as prescribed by the Board are applied. Transfers may also occur without explicit consent under the conditions specified in KVKK Arts. 5/2 and 6/3 (e.g., contract performance, legal obligations, legitimate interests). Recipients are contractually obligated to comply with data protection requirements.

6. Storage, Security, and Deletion of Personal Data

Storage: Data related to contracts and payments is stored for the periods required by the legislation of the Republic of Turkey and deleted or anonymized thereafter, unless otherwise required for tax or other legal obligations. Detailed retention periods and deletion procedures are outlined in the Personal Data Processing Notice.
Security: Data is protected with technical and administrative measures (encryption, access controls, regular audits, and staff training) in compliance with KVKK and related regulations (Regulation No. 30224). Security measures are regularly updated and audited. In case of a data breach, the Personal Data Protection Board and affected individuals are notified without delay and as soon as possible.
Deletion: Upon expiration of the storage period or at your request, data is irreversibly deleted using methods appropriate to the storage medium. Usage data related to digital products is processed only for dispute resolution and fraud prevention, based on legitimate interests, and for the necessary duration.

7. Your Rights Under KVKK
Pursuant to KVKK Art. 11, your rights include: learning whether your data is processed, requesting information about processing, requesting correction or deletion, obtaining information about data transfers, objecting to processing, and claiming compensation for damages. To exercise your rights, you may submit a written request or use other methods specified by KVKK to info@marinabelous.com; requests will be responded to within 30 days as per KVKK Art. 13. If you believe your rights have been violated, you may file a complaint with the Personal Data Protection Board.

8. Cookies and Similar Technologies
Essential cookies are used for website functionality and do not require consent; analytical and marketing cookies require your explicit consent. Marketing cookies may process user preferences and behavior as personal data; explicit consent is mandatory for these cookies. Analytical cookies use anonymized data to improve user experience. Cookie usage complies with KVKK and the Electronic Communications Privacy Directive. You may modify or withdraw your consent at any time via browser settings or the cookie management panel on our website.

9. Data Processing for Returns/Cancellations
Data provided during refund or cancellation requests is processed solely for the purpose of these procedures (e.g., refunds in Turkish Lira (₺), including 20% VAT, with conversion for Euro (€) payments based on the bank’s exchange rate) and, in accordance with the Mesafeli Satışlar Yönetmeliği (Regulation on Distance Sales), is deleted or anonymized after the periods required by the legislation of the Republic of Turkey, unless otherwise required to fulfill tax or other legal obligations (see Return and Cancellation Policy).

10. Policy Updates
Changes are published on marinabelous.com and take effect on the date of publication; significant changes are notified via e-mail within a reasonable period before taking effect.

11. Dispute Resolution
Disputes are subject to the jurisdiction of İstanbul Consumer Arbitration Committees and Consumer Courts. For KVKK violations, you may file a complaint with the Personal Data Protection Board. Turkish law applies to disputes arising from this Policy.

Last Updated: August 13, 2025