SANMAR DENIZCILIK A.S. (SANMAR SHIPYARDS) ONLINE PRIVACY POLICY

Our Commitment

Sanmar Denizcilik A.S. (Sanmar Shipyards) (“we”, “us” or “our”) is committed to maintaining the security, confidentiality and privacy of your personal information. This Policy documents our ongoing commitment to you.

Scope of Policy

This Policy applies to our collection, use and disclosure of your personal information through our website at sanmar.kliksamuray.com.tr This Policy does not impose any limits on the collection, use or disclosure of business contact information or certain publicly-available information. It does not apply to information relating to corporate or commercial entities.

By visiting our website or using any of our services available through our website, you agree that your personal information will be handled as described in this Policy. Your use of our websites or services, and any dispute over privacy, is subject to this Policy and our Terms of Use.

We may change this Policy from time to time, and these changes will be incorporated without notice into a revised Policy that will be posted at sanmar.kliksamuray.com.tr/privacy-policy/ in order to ensure that you will always have the most current information with respect to our privacy practices.

Information that we Collect

We collect information that you provide directly to us, such as when you set up an account on our site, when you sign up to receive communications from us, or when you otherwise communicate with us through our site or provide or post information to our site.

We may automatically collect the following information about your use of our website or services through cookies, web beacons, and other technologies:

• your domain name;
• your browser type and operating system;
• web pages you view;
• links you click;
• your IP address;

the length of time you visit our websites and or use our services; and the referring URL, or the webpage that led you to our website; We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Cookies

Cookies are small text files of information stored by your internet browser on your computer’s hard drive. We may use cookies to collect browsing data, for example, to keep track of your preferences and profile information and to collect general usage and volume statistical information. Our cookies do not collect personal, confidential information and are not spyware.

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our websites who disable cookies will be able to browse certain areas of the websites, but some features may not function.

Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our websites. We also may use other analytic means to evaluate our services. We use these tools to help us improve our products and services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.

Purposes

When collecting personal information, we will state the purpose of collection.

We may collect, use and disclose personal information as permitted or required by law, and to:

maintain, operate, troubleshoot and improve our website and services available through our website; provide and administer products and services you request, and to disclose the information for any purpose related to the provision of requested products and services; authenticate your identity; manage or transfer our assets or liabilities, for example, in the case of an acquisition or merger, the provision of security for a credit facility or the change of a supplier of products or services; maintain accurate customer records; protect us, yourself and others from fraud and error and to safeguard our business interests; comply with legal and regulatory requirements; and distribute to third parties including financial institutions, payment processors, lawyers, financial institutions and government licensing bodies for any of the above purposes. The collections, uses and disclosures listed above are a reasonably necessary part of your relationship with us. We may also collect, use and disclose your personal information to communicate with you for the purposes to which you have consented or as otherwise required or permitted by law.

When your personal information is to be used for a purpose not previously identified, we will disclose that the new purpose to you before such use, and we will seek your consent unless the use is authorized or required by law.

Consent

We will obtain your consent to collect, use or disclose personal information except where we are authorized or required by law to do so without consent. For example, we may collect, use or disclose personal information without your knowledge or consent where the information is publicly available, as defined by statute or regulation, or we are obtaining legal advice. Other exceptions may apply.

Your consent can be express, implied or given through an authorized representative. Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your personal information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise.

You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give us reasonable notice of withdrawal of consent. If you notify us that you withdraw consent, we will inform you of the likely consequences of that withdrawal of consent, which may include our inability to provide certain services for which that information is necessary.

Limits on Collection of Personal Information

We will not collect personal information indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We will also collect personal information as authorized by law.

Limits for Using, Disclosing and Retaining Personal Information

We will only use or disclose your personal information for the purposes set out above and as authorized by law.

We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision.

We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retaining the information and retention is no longer necessary for a legal or business purpose.

We will take due care when destroying personal information so as to prevent unauthorized access to the information.

Accuracy

We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete.

If you demonstrate that your personal information is inaccurate or incomplete, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.

When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.

Safeguarding Personal Information

We protect the personal information in our custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Some specific safeguards include: (i) physical measures such as locking filing cabinets; (ii) organizational measures such as restricting employee access to files and databases, as appropriate; (iii) electronic measures such as passwords and firewalls; and (iv) investigative measures where we have reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.

We will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by our suppliers and agents.

While we make every effort to ensure that your information is secure on our system, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk and your use of our website demonstrates your assumption of this risk.