We understand that your privacy is important to you and that you care about how your personal data is used. This Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

     1. WHO WE ARE

1. •      ZENAN JOY YATÇILIK SANYİ VE TİCARET LTD. ŞTİ. (“we”, “us” or “our”) are committed to protecting and respecting your privacy.
   • This policy (together with our Terms of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website joyyachting.com (Site) you are accepting and consenting to the practices described in this policy.
   • We provide this Site to help consumers both discover yacht charter and research their next vacation by combining details of ALL yachts for Charter with destination information, special offers, events and market news. We are not yacht brokers ourselves.
   • If you have any queries or comments about the policy, our use of your personal information or wish to unsubscribe from messages from us, please get in touch by emailing info@joyyachting.com or writing to us.
   • A reference to “you” or “your” is a reference to a user of the Site or any of our services.

1. 2. WHAT INFORMATION WE COLLECT
   • We may collect some or all of the following personal data (this may vary according to your relationship with us:
     • Name, email address, information about your preferences and interests, demographic information (such as your gender) as well as other information you directly give us on our site. In addition, we may also collect personal information from you when you correspond with us (for example, when you send us e-mail communications or by telephone). We may also further enrich your profile with additional data that is publicly available or, with your explicit permission, access more detailed information on alternative platforms (Instagram, Facebook etc).
     • We automatically log information about you and your computer. For example, when visiting our site, we log your computer operating system type, browser type, browser language, the website you visited before browsing to our site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our site.
   • We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Site to form part of Your Information. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and brokers) and may receive information about you from them.
   • On our Site, the forms where you might enter personal information have tick box options to enable you to accept or decline to our use of Your Information for marketing purposes. Your most recently submitted form will be used as your current consent status. If you are a registered user, but not signed in when you submit a form, we won’t be able to use your saved settings. Your consent choice will be deemed to be as per the form you submit at the time.
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2. 3. HOW WE USE YOUR INFORMATION
   • Under the GDPR, we must always have a lawful basis for using personal data (Your Information). This may be because the data is necessary to provide you with access to all parts of this Site, or for our performance of a contract with you, or because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it.
   • Your personal data may be used for one of the following purposes:
     • Providing and managing your account.
     • Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
     • Personalising and tailoring our products and services for you.
     • Communicating with you. This may include responding to emails or calls from you.
     • Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by clicking the appropriate unsubscribe link within the communication.
     • We may aggregate the information to identify patterns which we can use in our marketing and to help us develop, administer, support and improve our services and features.
     • Where you have consented to being contacted by third parties including yacht brokers, we may make Your Information available to them to enable them to produce a more personalised service to you.
     • to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
     • to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
     • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
     • to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them.
     • to enforce our Terms of Use and as part of our efforts to keep our Site safe and secure;
     • details of your last search are sent to the third-party yacht broker, business partner or advertiser to help them find yachts that match your requirements more closely. If you are a registered user and signed in, your settings will be included to help them provide a more personalised services to you.
     • If you call us or a third-party yacht broker, business partners or advertisers, information regarding the time and date of the call, its status and your telephone number will be made available to them. Your phone calls may be recorded for training and monitoring purposes. The recordings will only be available to the partner or advertiser you contacted and our employees.
     • If you decide to save yachts you are interested in on the Site, we can identify which yachts you have saved. These details may be anonymously aggregated to indicate how many users have saved a particular yacht, but we will not make available to third parties any personal data relating to which users have saved which yachts.
     • If you decide to save searches and/or use the yacht alerts feature to receive notification when new yachts matching your criteria are added to this Site, we will record the settings you use and which yachts have been sent to you. We do not make any information about any yacht that has been sent to you available to our partners, advertisers or third parties
     • With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and or telephone, text message and post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
     • Our partners service uses the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us by emailing info@joyyachting.com or writing to us.The following automated decision-making and profiling method(s) may be used:
       Should you place a charter enquiry through the Site we will use elements such as your browser language, location, timezone, how long you spent on a page, access times, your preferences, budgets and regions of interest and previous enquires to help us find and match a third-party yacht broker who may be best placed to help assist you with your specific requirements.
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3. 4. WHO ELSE HAS ACCESS TO YOUR INFORMATION
   • We may sometimes contract with the following third parties to supply products and or services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold. By using this Site, you consent to us providing Your Information to the third parties licensed by us to provide such services.
   • If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law. We will not allow the third party to use Your Information commercially without your consent.
   • If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR.
   • In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
   • If we enter into a joint venture with or our business is sold to or merged with another business, Your Information may be disclosed and ultimately transferred to our new business partners or owners.
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4. 5. WHAT ARE MY RIGHTS?
   • Under the GDPR, you have the following rights, which we will always work to uphold:
     • The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us by emailing info@joyyachting.com or writing to us.
     • The right to access the personal data we hold about you. Part 6. will tell you how to do this.
     • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using by emailing info@joyyachting.com or writing to us to find out more.
     • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact by emailing info@joyyachting.com or writing to us.
     • The right to restrict (i.e. prevent) the processing of your personal data.
     • The right to object to us using your personal data for a particular purpose or purposes.
     • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
     • Rights relating to automated decision-making and profiling. Part 3. explains more about how we use your personal data, including automated decision-making and profiling.
   • For more information about our use of your personal data or exercising your rights as outlined above, please contact us by emailing info@joyyachting.com or writing to us.
   • Further information about your rights can also be obtained from the Information Commissioner’s Office.
   • If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
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6. 6. ACCESSING YOUR PERSONAL DATA
   • If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
   • All subject access requests should be made in writing and sent by emailing info@joyyachting.com or writing to us.
   • There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
   • We will respond to your subject access request within 3 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

COOKIE POLICY

1. WHAT ARE THEY?
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   1. Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. By continuing to browse the Site, you are agreeing to our use of cookies.
   2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
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   1. We use the following cookies:
4.  
   1. 1. Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, maintain user sessions or log in to your account.
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   1. 2. Local storage/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
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      1. 3. Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
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      1. 4. Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
      2. You can find more information about the individual cookies we use and the purposes for which we use them in the table below.
      3. Whilst we make every effort to recognise and respect your choices; it is possible that not all cookies and similar methods of data capture will be covered by these settings. If this is a concern to you then we recommend that you change the settings in your browser. If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings. If not, you may wish to visit www.aboutcookies.org, which should help.