CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA
1- GENERAL INFORMATION ABOUT THE LAW
As the data controller, NEGMAR SHIPPING INVESTMENT INC., in order to comply with the Law on the Protection of Personal Data No. 6698 (“PDP Law”) and related communiques, this Clarification Text aims to inform the relevant people about the personal data processing activities carried out by Negmar Denizcilik Yatırım in accordance with the said Law and the personal data of which are processed on real people (“Relevant Person”).
1.1 Definitions
– Explicit Consent: Consent on a specific subject, based on information and expressed with free will.
– Anonymization: Making personal data incapable of being associated with an identified or identifiable real person in any way, even by pairing it with other data.
– Personal Data: Any information relating to an identified or identifiable real person.
– Personal Data Owner: The real person whose personal data is processed.
– Processing of Personal Data: Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available personal data fully or partially automatically or non-automatically provided that it is a part of any data recording system. All kinds of operations performed on data such as classification or prevention of use.
– PDP (Personal Data Protection) Law: The Law on Protection of Personal Data No. 6698, dated March 24, 2016, published in the Official Gazette dated 7 April 2016 and numbered 29677.
– PDPL Board: Personal Data Protection Board
– PDPL Authority: Personal Data Protection Authority
2-WHAT ARE THE PURPOSE AND LEGAL REASONS FOR THE PROCESSING OF YOUR PERSONAL DATA?
In order to serve you better and within the framework of the legal obligation arising from the Personal Data Protection Law No. 6698 and the relevant legislation; requests your personal data (name, surname, gender, age, GSM number, e-mail address, etc.) that will enable you to fulfill the said purpose and legal obligations. When you request ‘contact us’ to get customer support or technical support service; When you subscribe to Negmar Shipping’s newsletter; When you participate in feedback, surveys and/or use Negmar Shipping sites, your data is processed by Negmar Shipping in accordance with the provisions of the relevant legislation. When you download the Negmar Denizcilik mobile application through Platforms such as App Store and Google Play Store, Negmar Shipping collects certain personal data from you and/or your device.
3- COLLECTED DATA AND COLLECTION METHOD
Negmar Shipping, collects data on your advertising ID (IDFA for IOS devices and GAID for Android devices), other device identifiers (IDFV for IOS devices), device identifier, operating system, model, manufacturer information, hardware type, operating system version, memory usage, country, time zone and preferred language information, internet protocol (IP) number, location information based on your IP address, operator and browser information, and data about installation and first launch time of the application. The above-mentioned advertising IDs (IDFA and GAID) are unique identifiers for mobile devices that advertisers use for personalized advertising that are consistent across all mobile apps, thus allowing cross-app tracking. You can disable this option by enabling the “limit ad tracking” option in the privacy settings of Apple devices. On Google Android devices, you can change your ad settings by enabling the “disable ad personalization” option. Advertising IDs are non-permanent identifiers that are uniquely associated with your device.
Negmar Shipping does not collect your personal data such as your name, surname, credit card number and e-mail address that you share with the Platforms for payment, only the payment information of the products you purchase is shared with us to fulfill your order.
4-TO WHOM AND FOR WHAT PURPOSES DO WE TRANSFER YOUR PERSONAL DATA?
In order to provide better service to the users and within the framework of legal obligations, Negmar Shipping; will collect, process, securely store your location information obtained through your IP address; your device and browser information; your browsing information and in-app or out-of-app user actions we obtain through mobile analytics or Google Analytics; and share it with third parties on the condition of anonymizing all or part of your aforementioned information.
In addition, when you submit your CV to our website to apply for a job and upload your CV to the Negmar Shipping website, your general and special personal data can be processed.
Based on your your explicit consent, profiling within the framework of usage habits, expectations, personalization and needs, ensuring security and supervision, developing new service lines, providing and offering various advantages to you, management of customer evaluation and complaint processes, compliance processes, human resources processes and similar services, sending all kinds of communication messages for sales, marketing and similar purposes, recording e-mail addresses and other necessary information for communication, offering special advertisements, campaigns and other benefits to our users, customer segmentation in line with the data obtained through all kinds of marketing and advertising activities, data mining and other statistical analyses, developing and improving customer data quality, taking loyalty actions for customer management, designing and managing cross-selling and regaining lost customers, offering suggestions to our customers by our contracted institutions and solution partners, informing our customers about our services, providing our users with appropriate services, personal data collected during the recruitment process of employee candidates and special quality personal data collected according to the nature of the job by Negmar Shipping; execution of the activities determined by the human resources policy, recruitment, evaluation of the qualification, experience and interest of the candidate for the open position, checking the accuracy of the information submitted by the candidate, if necessary, contacting third parties to research the candidate, contacting the candidate about the application and recruitment process, is collected, transferred, processed, used and stored by Negmar Shipping and its business partners by taking information security measures within the scope of Articles 4, 5 and 6 of the PDP Law.
Personal data belonging to customers, can be shared with real persons or private law legal entities, our business partners, our suppliers, and legally authorized public institutions and organizations within the framework of its terms and purposes, specified in the 8th and 9th articles of the Law, including the execution of the necessary work by the business units to benefit the persons concerned from the products and services offered by Negmar Shipping Investment Inc., and the execution of the relevant business processes, the planning and execution of commercial and / or business strategies.
Your Personal Data can be collected which may be transmitted verbally, in writing or electronically, through automatic or non-automatic methods within the framework of our company’s commercial activities, through our website, social media channels, the parties with which we have business relations and/or the parties with which we receive services as a complement to our activities, contracted organizations and other similar channels. Your personal data is also within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law and “fulfillment of legal obligations”, “Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract”, It may be processed and shared in line with legal reasons and purposes, “obligatory for the legitimate interest of the data controller”.
Your processed personal data in question may also be shared with group companies belonging to Negmar Shipping.
Since we use Microsoft Outlook systems as e-mail service, your personal data is transferred to Microsoft’s secure servers for virus scanning, but is stored on Company servers at the end of the process.
5 – WHAT ARE YOUR RIGHTS UNDER THE PERSONAL DATA PROTECTION LAW NO. 6698?
By applying to Negmar Shipping Investment Inc., your personal data;
1.a) learning whether it has been processed or not,
2.b) requesting information if processed,
3.c) learning the purpose of processing and whether it is used in accordance with its purpose,
ç) to know the third parties to whom it is transferred in the country/abroad,
1.d) requesting correction if it is incomplete/wrongly processed,
2.e) Requesting deletion/destruction within the framework of the conditions stipulated in Article 7 of the Personal Data Protection Law No. 6698,
3.f) To request notification of the transactions made in accordance with subparagraphs (d) and (e) above, to the third parties to whom it has been transferred,
4.g) objecting to the emergence of a result against you due to the analysis exclusively by automated systems,
ğ) You have the right to demand the compensation of the damage in case you suffer damage due to unlawful processing.
Pursuant to article 11 of the Personal Data Protection Law No. 6698, together with the information/documents proving your identity;
– send a written petition to our company address to the attention of the Human Resources department,
– you can send an e-mail from your KEP address to the Registered Electronic Mail (KEP) address registered on our company’s website,
– you can send an e-mail to negmar@negmar.com from your secure electronic signature or from your e-mail address registered in our system. Your application must be made in accordance with the second paragraph of Article 5, titled “Application Procedure”, of the “Communique on Application Procedures and Principles to the Data Controller”. Your application will be evaluated by our company and concluded free of charge within 30 (thirty) days at the latest, depending on the nature of your request; however, if the transaction requires an additional cost, you may be charged a fee according to the tariff to be determined by the Personal Data Protection Board.
Negmar Shipping Investment Inc. takes necessary measures to protect personal data from unauthorized access or loss, misuse, disclosure, alteration or destruction, undertakes to keep your personal data confidential, to take all necessary technical and administrative measures for ensuring confidentiality and security, and to show due diligence.
Your personal data processed for the purposes specified in this “Clarification Text”; It can be deleted/destroyed/anonymized and continued to be used by us when the purpose that requires processing according to Article 7/f.1 of Law No. 6698 is no longer valid and the periods determined by other legislation expire.