KVKK PRIVACY NOTICE

1. Data controller

The data controller responsible for this website is Sunorama Cruises Gemicilik Hizmetleri A.Ş. (“Sunorama Cruises” or the “Company”).

Address: Caddebostan Mah. Bağdat Cad. No: 311 Mengüç Apt. D: 1-2, Kadıköy / İstanbul, Türkiye
Telephone: 444 80 92 / +90 216 359 82 22
Email: cruise@rccl.com.tr
Registered Electronic Mail (KEP): sunoramacruises@hs01.kep.tr

2. Personal data that may be processed

• Transaction security data: your IP address, access time, requested page, browser and device information, and error and security logs.
• Cookie preference data: whether you have allowed social media content, together with the date and version of your preference.
• Enquiry and contact data: if you contact us using a WhatsApp link, the name, telephone number, message content and travel preferences that you choose to share.
• Third-party content data: device, connection and cookie data that Instagram/Meta may collect if you enable Instagram content with your explicit consent.

This promotional website does not offer membership, process payments or include a contact form that sends data directly to us.

3. Purposes and legal grounds for processing

• Providing and securing the website, and preventing errors and misuse, is based on the Company’s legitimate interests under Article 5(2)(f) of the KVKK and, where applicable, compliance with a legal obligation under Article 5(2)(ç).
• Recording and demonstrably managing your cookie preferences is based on compliance with legal obligations and the Company’s legitimate interests.
• Displaying Instagram posts within the website is based solely on your explicit consent under Article 5(1) of the KVKK.
• Responding to an enquiry submitted through WhatsApp and managing quotation and pre-booking processes is based on processing that is directly related to establishing or performing a contract under Article 5(2)(c) of the KVKK. Separate consent will be obtained where required for promotional commercial communications.

4. Disclosure and transfer of personal data

Limited to the purposes described above, your personal data may be transferred to Cloudflare, which provides hosting and content-delivery services; to Instagram/Meta with your explicit consent; to WhatsApp/Meta if you choose to contact us through WhatsApp; and to legally authorized public bodies.

If a transfer abroad is involved, the Company will act in accordance with the transfer conditions and appropriate safeguards set out in Article 9 of the KVKK. The website does not connect to Instagram content unless you have given explicit consent.

5. Collection methods and retention

Personal data is collected electronically through web-server and security logs, preference storage in your browser, third-party content loaded with your explicit consent, and communications that you initiate through WhatsApp.

Your cookie preference is stored in your browser for 180 days. Other data is retained for the period necessary for the relevant processing purpose and for any period specified in the Company’s retention and destruction policy or applicable law. At the end of that period, the data is erased, destroyed or anonymized.

6. Your rights under Article 11 of the KVKK

You may apply to the Company to learn whether your personal data is being processed; request information if it has been processed; learn the purpose of processing and whether the data is used in accordance with that purpose; learn which third parties in Türkiye or abroad have received it; request the correction of incomplete or inaccurate data; request erasure or destruction where the statutory conditions are met; request that correction, erasure or destruction be notified to third parties to whom the data has been transferred; object to an adverse outcome arising solely from automated analysis; and claim compensation if you suffer damage due to unlawful processing.

7. How to exercise your rights

You may submit a request under the KVKK, including sufficient information to verify your identity and describe your request, in writing to the postal address above; via the registered electronic mail address sunoramacruises@hs01.kep.tr; or, using an email address already registered in the Company’s systems, to cruise@rccl.com.tr. Requests will be answered as soon as possible and no later than 30 days, depending on their nature.