Through this Privacy Policy, Negmar Shipping Investment Inc. (Negmar Shipping) residing in Altunizade Mah. Ord. Prof. Fahrettin Kerim Gökay Cad. No:35/1 Üsküdar/Istanbul, informs you about the types of personal data collected as part of the services offered, the manner in which such personal data is used, the parties with whom Negmar Shipping may share such personal data, your rights regarding your personal data processed by Negmar Denizcilik and how you can exercise these rights, and how you can change your positive or negative preferences if you contact us.

The policy has been published on our company’s website and made available to the public. In case of any conflict between the regulations included in this Policy and the current legislation, the provisions of the legislation shall apply, especially the Law No. 6698. The company reserves the right to make changes to this Policy in line with legal regulations. The latest version of the Policy can be accessed on the website www.negmar.com.

In order to benefit from the content of the mobile application and website, all rights of which belong to Negmar Shipping Investment Inc. or its subsidiaries, you need to register first. The communication procedures for your registration, payment and login processes are secured by the security certificates owned by Negmar Shipping (website/application).

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. Your Processed Personal Data and the Purpose and Basis of Personal Data Processing

2.1. Services served in Negmar Shipping online platform, processes your personal data (name, last name, GSM number, e-mail address, etc.) partially or completely automatically or non-automatically as a part of the data recording system in order to fulfill its obligations, to provide you with a good service and to perform statistical studies within the framework of the Law No. 6698 on the Protection of Personal Data (“KVKK”) and the legal rules specified in the relevant legislation.

Your personal data is processed by Negmar Shipping in accordance with the provisions of the relevant legislations, but not limited to those listed; 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 Denizcilik’s websites. When you download the Negmar Shipping mobile application through Platforms such as App Store and Google Play Store, Negmar Shipping collects certain personal data from you and/or your device.

Again in this context, 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.

2.2. Your processed personal data in question may be forwarded to the relevant institution if requested by the authorized public institutions and organizations in the country or abroad, as specified in Articles 8 and 9 of the relevant law. This process will only take place within the framework of the above-mentioned purposes and will also be implemented within the framework of legal rules.

2.3. Your processed personal data in question may also be shared with group companies belonging to Negmar Shipping.

3. Your Rights Regarding Your Personal Data

3.1. The user can save his/her rights within the framework of Article 11 of the PDP Law No. 6698 and has the right to change or update this data at any time. In this context, in order to learn which of your data is processed, whether it is used for the specified processing purpose, to learn about the third parties in the country or abroad to whom your personal data is transferred, or if there is any change in your outdated or incorrectly processed personal data or your processed personal data, update, change or delete this data, you can request the said actions to be taken by sending an e-mail to negmar@negmar.com in order to request the notification of this situation to the third parties to whom your personal data has been transferred.

3.2. The above-mentioned changes and updates can be made via the request form on the website negmar@negmar.com and a wet-signed copy of your request delivered to company HQ at Altunizade Mah. Ord. Prof. Fahrettin Kerim Gokay Cad. No: 35/1 Üsküdar/Istanbul, along with the documents that will help you determine your identity, send it by a notary public or by other methods specified in the PDP Law, or you can send it to the negmar@negmar.com e-mail address with a secure e-signature.

3.3. You have the right to learn whether your personal data is processed with the information that will help you determine your identity in order to exercise your rights within the scope of PDP Law, to request information about it if it has been processed, to learn the purpose of processing and whether they are used in accordance with its purpose, to correct it if it is incomplete or wrongly processed and to notify the transferred third parties, requesting that it be deleted or destroyed within the framework of the conditions stipulated in Article 7 of the PDP Law, requesting that it be notified to the third parties to which it has been transferred, objecting to the emergence of a result against you due to the analysis exclusively by automatic systems, and requesting the compensation of the damage in case you suffer damage due to unlawful processing.

3.4. Regarding your request, Negmar Shipping may request some information from you for confirmation. Negmar Shipping reserves all its rights regarding its obligations to keep your personal data processed within the scope of PDP Law for the period stipulated in the relevant legislation and laws. You can access Negmar Shipping’s policy on the protection and destruction of your personal data on its website.

4. Retention Period of Personal Data

Your personal data you provide to Negmar Shipping is kept for 3 years from the end of use. The retention period of the personal data provided to Negmar Shipping user accounts is determined according to the continuity in the provision of services. In the event that the period expires, your personal data will be deleted, destroyed or anonymized by Negmar Shipping or upon your request. If you request the extension or shortening of the designated retention periods, this request is subject to Article 2.2 of this Confidentiality Agreement. You can send it to the company as explained in the article.

5. Sharing of Personal Data with Official Authorities

Negmar Shipping may share the User’s personal data with public institutions and organizations that are legally authorized to request this information for your security and for Negmar Shipping to fulfill its legal obligations. This process is done within the scope of similar issues such as, but not limited to, the fight against crime, the threat of state and public security, in cases where Negmar Shipping is legally or administratively liable to report or provide information.

6. Measures Regarding the Protection of Personal Data

6.1. The application, user information and various other personal data on your device cannot be shared with third parties in violation of the relevant law. The User and Negmar Shipping are jointly responsible for the security of this data within the scope of the relevant law.

6.2. Negmar Shipping personal data; takes essential measures in accordance with Article 12 of the Personal Data Protection Law No. 6698 in order to protect against the risks of unauthorized access or disclosure, misuse, loss, alteration or destruction of this information. Negmar Shipping undertakes to keep your personal data confidential, to take all necessary technical and administrative measures to ensure confidentiality and safety, and to act with care. Although Negmar Shipping takes the necessary information security measures, if personal data is damaged or in the hands of third parties as a result of cyber attacks on the website and mobile application, Negmar Shipping immediately notifies you and the Personal Data Protection Board and takes the necessary measures.

6.3. We point out that if the message in question is not encrypted in e-mail communication, the security of the message cannot be guaranteed and the user is responsible for the security of the e-mails you send. It is possible to provide links from mobile applications and websites to other websites that do not belong to Negmar Shipping. In case of visiting any of these websites, it is the User’s responsibility to review the accuracy and reliability of that website.

7. Changes to the Privacy Policy and Personal Data Protection Policy and Communication Permission

Negmar Shipping can make changes in this Privacy Policy and Personal Data Protection Policy at any time. These changes will become effective immediately upon posting of the amended new Privacy Policy on the www.negmar.com website. Necessary information will be provided to you, our users, in order to be aware of the changes in this Privacy Policy. Users can always change their User/Personal information and communication preferences by sending an e-mail to negmar@negmar.com or via the application.

8. Applicable Law, Authorized Court and Enforcement Offices

This Privacy Policy is subject to the laws of the Republic of Turkey and the competent authority in resolving any disputes that may arise from the application of this policy is Istanbul Anadolu Courts and Enforcement Offices.

9. Communication Permission

By accepting this Privacy Policy, by giving consent to be shared with us, your personal data on our website www.negmar.com can be provided and presented to you with various advantages and for special promotion, advertisement, marketing, survey, promotion, sales and similar purposes such as making all kinds of electronic communication via telephone, short message (SMS), e-mail and similar means and sending other communication messages; You consent to the collection, processing, storage, use and transfer of Negmar Shipping to third parties with whom it has a contractual relationship.

10. Cookie Policy

During the use of Negmar Shipping’s website and mobile application; In order to improve our services and to provide a better quality and effective service, some cookies may be used within the scope of our legitimate interests, taking into account that your fundamental rights and freedoms are not harmed. For detailed information on this subject, you can reach our Negmar Shipping cookie policy on our website www.negmar.com. The User irrevocably accepts, declares and undertakes that when he/she accepts this User and confidentiality agreement, he/she understands that cookies are used on the websites and mobile applications of Negmar Shipping and will not claim any compensation from Negmar Shipping in any way whatsoever.

11.Other Provisions

11.1. The copyrights of the contents, materials, information, visual elements and their arrangement in the application and website belong to Negmar Shipping. They may not be copied, rented, distributed, modified, reproduced, sublicensed, used for commercial purposes, reverse engineered, decompiled or disassembled.

11.2. The information provided on these websites is provided “as is” and “as available”. Negmar Shipping does not guarantee the accuracy, adequacy and completeness of this information and publicly disclaims any liability for errors or omissions in this information. Not violating the rights of third parties with this information; makes no warranties of any kind, implied, express or legal, including, but not limited to, warranties of ownership, fitness for a particular purpose, and/or computer virus free. Including direct or indirect damages, losses and expenses arising as a result of any performance failure, defect, defect, interruption, error, delay in operation and/or transfer, computer virus and/or line and/or system failure during the use of the mobile application and website. Negmar Shipping cannot be held responsible for any loss or damage, including but not limited to these, even if they have been informed of the possibility of such damage and loss.