Privacy Policy

Last updated: 20 July 2026

1. Introduction

Marlines Crew Management Denizcilik ve Lojistik Hizmetleri Sanayi Ticaret Ltd. Şti. (“Marlines Crew Management”, “we”, “us”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit our website or use our services.

2. Data Controller

  • Legal entity: Marlines Crew Management Denizcilik ve Lojistik Hizmetleri Sanayi Ticaret Ltd. Şti.
  • Registered address: Ataköy 7-8-9-10. Kısım Mah., Çobançeşme E-5 Yan Yol Cad., A Blok No: 22/1, İç Kapı No: 198, Bakırköy / İstanbul, Türkiye
  • Tax office / no: Bakırköy Tax Office (Bakırköy Vergi Dairesi) — VKN 6121721831
  • Registration date: 12 December 2023
  • Contact: operation@marlinesmaritime.com

3. Information We Collect

  • Identity data: Full name, nationality, date of birth, national ID / passport number
  • Contact data: Email address, telephone number, postal address
  • Professional data: Maritime qualifications, certificates, sea service records, CV, discharge book
  • Special categories: Medical fitness certificate (MLC A1.2), criminal record extract where required — with explicit consent or legal basis only
  • Photograph: Passport / discharge book identification
  • Technical data: IP address, browser type, device information, pages visited (cookies)
  • Communication data: Messages submitted via our contact / application forms

4. How We Use Your Data

  • Processing job applications and seafarer recruitment / placement
  • Preparing and performing the Seafarer Employment Agreement (SEA)
  • Complying with legal and regulatory obligations (MLC 2006, STCW, flag state / port state requirements)
  • Payroll, allotment, insurance and social security administration
  • Travel, visa and joining logistics
  • Client service delivery and internal record-keeping
  • Fraud prevention, safety of navigation and grievance handling
  • Responding to enquiries and improving our services

5. Legal Basis for Processing

  • Consent — where explicit consent is given for specific activities (e.g., talent pool retention, marketing)
  • Contractual necessity — where required for the SEA or client agreement
  • Legal obligation — MLC 2006, STCW, Turkish flag / labour / tax law
  • Legitimate interests — provided they do not override your fundamental rights (fraud prevention, service quality)

6. Data Sharing

  • Shipowner and shipmanager clients — for the specific engagement
  • Flag state administrations, port state control, T.C. Ministry of Transport and Infrastructure — Directorate General of Maritime Affairs
  • Classification societies conducting MLC SRPS audits (Korean Register — KR)
  • Approved medical practitioners
  • Travel, visa and insurance providers
  • Cloud, IT and security service providers under appropriate contractual safeguards
  • Competent public authorities where legally required

We will never sell your personal data to third parties for marketing purposes.

7. International Data Transfers

Due to the international nature of maritime operations, personal data may be transferred to countries outside the EU/EEA and Türkiye. Where this occurs, we ensure appropriate safeguards: adequacy decisions, Standard Contractual Clauses approved by the European Commission, or explicit consent (as applicable under KVKK Art. 9 and GDPR Chapter V).

8. Data Retention

  • Unsuccessful applicant CV: up to 2 years (with consent for talent pool retention)
  • Active seafarer files: contract duration + 5 years per MLC 2006
  • Accounting, tax, insurance records: 10 years
  • Website cookies: as detailed in our Cookie Policy

9. No Recruitment Fees

In line with MLC 2006 Standard A1.4(5)(b), Marlines does not charge seafarers directly or indirectly for recruitment or placement, other than the statutory cost of a national medical certificate, discharge book and passport.

10. Data Protection Impact Assessments

We conduct Data Protection Impact Assessments (DPIAs) for processing activities that are likely to result in high risk to the rights and freedoms of individuals, particularly in relation to seafarer recruitment and health data.

11. Breach Notification

In the event of a personal data breach that is likely to result in risk to the rights and freedoms of individuals, we notify the competent supervisory authority (KVKK / EU regulator) within 72 hours and affected individuals without undue delay.

12. Your Rights

  • Right of Access — obtain confirmation and a copy of your data
  • Right to Rectification — have inaccurate data corrected
  • Right to Erasure — request deletion where legal grounds permit
  • Right to Restriction — restrict processing in certain circumstances
  • Right to Data Portability — receive your data in a machine-readable format (GDPR)
  • Right to Object — object to processing based on legitimate interests or direct marketing
  • Withdraw Consent — at any time, without affecting prior lawful processing
  • Lodge a complaint with the Turkish Data Protection Authority (KVKK — www.kvkk.gov.tr) or your local EU/EEA supervisory authority

13. Exercising Your Rights

To exercise any of your rights, please contact operation@marlinesmaritime.com or complete the Data Subject Request Form. We respond within 30 days.

14. Security

We implement appropriate technical and organisational measures — including access controls, encryption in transit, staff training and periodic reviews — aligned with our ISO 9001:2015 quality management system and MLC 2006 requirements, to protect your personal data against unauthorised access, alteration, disclosure or destruction.

15. Cookies

Please refer to our Cookie Policy for details of cookies used on this website and how to manage your preferences.

16. Updates

We may update this Privacy Policy from time to time. The current version is always available on this page.