ABOUT THE PROCESSING OF PERSONAL DATA

1. Identity of Our Company's Data Controller

As Navlungo Lojistik ve Teknoloji A.Ş. (“Navlungo” or “Company”), we show the utmost sensitivity regarding the security and confidentiality of your personal data. With this awareness, we present the following matters to your attention within the scope of our obligation to inform you, in order to ensure that we act in accordance with the Law on the Protection of Personal Data No. 6698 (“Law”) regarding the personal data we obtain in our capacity as data controller.

2. Personal Data We Process

Within the scope of the contractual or commercial relationship in which you are or will be involved with our Company, your name-surname, T.C. identity number, IBAN number, financial data, Tax number, business address, telephone number, fax number, e-mail address, signature, salary information of your employees, name-surname, T.C. identity numbers, if you are in cooperation with our Company as a shipper, your cargo content information, all data you have entered into the website www.navlungo.com while benefiting from the services offered by the Company, financial and identity data, your voice recordings taken by our call centers in case of your support request within the scope of the service you receive, and your conversation history in case online support is provided (all together “Personal Data”) are processed.

3. Transfer of Personal Data

Your personal data may be transferred to official institutions, third parties from whom our Company receives services or provides services, and third parties from whom support is received in areas such as storage, archiving, information technology support (server, hosting, program, cloud computing), and security, within the scope of the Law and related regulations, for the purposes explained in Article 2 of this Clarification Text, depending on and limited to the reason requiring its transfer.

4. Processing Method and Legal Basis of Your Personal Data

Your personal data may be collected automatically or non-automatically, for the purposes specified above, in accordance with the basic principles stipulated in the Law and on condition that they comply with the principles specified in Article 4 of the Law, based on and limited to the specified legal grounds: (i) where clearly provided for in the laws or the processing of our data is mandatory, (ii) for the fulfillment of our Company's legal obligations, (iii) for the establishment of a contract between you and us or the performance of an already existing contract, (iv) for the establishment of a right, or (v) for the legitimate interests of our Company, provided that it does not harm your fundamental rights and obligations; from information submitted by you personally verbally or in writing, or through closed-circuit camera recording systems located in our Company.

Your Personal Data is processed on the legal ground that it is necessary to process the personal data of the parties to the contract for the establishment and lawful execution of the commercial and/or contractual relationship between us and the Company; and on the legal grounds of being clearly provided for in the laws and the fulfillment of legal obligations in order to meet obligations under the legislation in force, including primarily the Tax Procedure Law No. 213, the Turkish Code of Obligations No. 6098, and the Turkish Commercial Code No. 6102 and the secondary legislation issued based on these. In addition, your Personal Data is processed on the legal ground that data processing is mandatory for the legitimate interests of the Company, which is the data controller, in order for our Company to maintain its existence and continue its commercial activities and to ensure communication between us, provided that no harm is done to your fundamental rights and freedoms.

In processing your Personal Data, the Company acts in accordance with the data processing principles and obligations specified within the scope of the relevant legislation, particularly the Constitution of the Republic of Turkey, the international agreements to which our country is a party, and the KVKK.

5. Purposes of Processing Your Personal Data

Your collected personal data will be processed within the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law, for the purposes of carrying out the necessary work by our business units and executing the relevant business processes to ensure that personal data owners benefit from the products and services offered by the Company, carrying out the necessary work by our relevant business units to realize the commercial activities carried out by the Company and executing the business processes related thereto, ensuring the legal, technical, and commercial-occupational safety of the Company and the persons in business relationship with the Company, planning and executing the commercial and/or business strategies of the Company, and planning and executing the activities necessary to suggest and introduce the products and services offered by the Company to personal data owners by customizing them according to the tastes, usage habits, and needs of the personal data owners.

6. How Do We Protect Your Personal Data?

Our Company takes all necessary technical and administrative measures in accordance with the KVK legislation in order to prevent unauthorized access to your personal data, erroneous processing, disclosure, alteration/deletion of your personal data for unlawful reasons, and to ensure its protection and security.
In case your personal data is damaged and/or captured/disclosed by third parties as a result of attacks on our Company's servers and/or other systems, our Company will immediately inform you and the Personal Data Protection Board.

Personal data obtained within the scope of our processing purposes is processed and stored within the scope of our processing purposes and applicable laws.

Your personal data is deleted, destroyed, or anonymized in accordance with our Personal Data Retention and Destruction Policy; (i) if our processing purposes have completely ended, (ii) at the end of the period stipulated in the law or upon your request.

7. Your Rights as a Data Subject Under KVKK

Within the scope of the Law, you have the rights to: (i) learn whether your personal data is processed, (ii) request information if your personal data has been processed, learn the purpose of processing your personal data and whether they are used in accordance with their purpose, (iii) know the third parties to whom your personal data is transferred at home or abroad, request correction of your personal data if it is processed incompletely or incorrectly, (iv) request deletion or destruction of your personal data, (v) request notification of the transactions regarding the correction of your personal data if it is processed incompletely or incorrectly and/or the deletion or destruction of personal data to third parties to whom your personal data has been transferred, (vi) object to the occurrence of a result against you by analyzing your processed data exclusively through automatic systems, (vii) request compensation for the damage in case you suffer damage due to unlawful processing of your personal data.

8. Submitting Your Requests Within the Scope of Personal Data Protection

In order for you to exercise your rights listed in Article 11 of the Law within the scope of the Law, you can obtain the Information Request Form we have prepared from the Navlungo Information Request Form link.
Do not forget to fill in, sign, and share the Information Request and Application Form with our company as specified in the form.

You can deliver the Information Request and Application Form;

• In person, by ensuring your identity verification, at our company's address: 15 Temmuz Mahallesi, Gülbahar Caddesi, 1500. Sokak No:16 Güneşli-Bağcılar/Istanbul; or via registered mail to the same address,

• To our Company's registered e-mail address [email protected]; or

• With your secure electronic or mobile signature, to our Company's address [email protected] or through other methods specified in the Law and relevant legislation.

Our Company, in accordance with Article 13 of the Law, will conclude application requests, depending on the nature of the request and within 30 (thirty) days at the latest. If the transaction requires a cost, the tariff determined by the Personal Data Protection Board will be applied. In case the request is rejected, the reason/reasons for rejection will be justified in writing or electronically. You can find detailed information regarding the evaluation process of application requests in the Personal Data Protection and Processing Policy, which you can access via https://navlungo.com/kisisel-veri-politikalari.

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