ParkPalet Privacy and Disclosure Text

The purpose of this Privacy Policy and Disclosure Text ("Policy") is to inform the natural person and legal entity users and visitors ("User/s" "Customer/s", "Visitor/s" or "You") of the website with the address "www.navlungo.com" ("Site"), which is managed by Navlungo Lojistik ve Teknoloji Anonim Şirketi ("Company"), about the terms and conditions regarding the processing of personal data provided to the Company and/or obtained from the employees and officials of legal entity Users and natural person Users during the stage of using the Site, for the services provided through the Site ("Services"). In interpreting the expressions not defined in this Policy, the definitions in the User Agreement ("Agreement") published on the Site shall be taken into account.

You can feel safe while using the Site. However, please remember that no system is completely secure. Even if we take all necessary steps to protect your data, there is always a possibility of being left without protection. For this reason, we would like to remind you that you must be very careful when sharing your personal data. Processing of data submitted by you without the request of the Company, other than the data requested by the Company, shall not be counted as personal data processed by the Company within the scope of this Policy. For this reason, we strongly warn you not to share your images and other personal data not requested by the Company, including but not limited to those listed, via e-mail, messaging, or any other communication channel.

Which of Your Data Is Processed?

Under this heading, the collected data processed within the scope of the services offered by the Company and deemed personal data in accordance with the Law on the Protection of Personal Data No. 6698 ("Law") belonging to the Users, data other than personal data, and data collected through cookies are listed below in groups. Unless explicitly stated otherwise, the expression "personal data" under the terms and conditions presented in this Policy includes the information below.

• Personal Data:

• Data Collected for Membership Transactions:

• Data Collected from Natural Person Users:

Identification Details: Name, surname

Contact Details: E-mail address, phone number, address details

Financial Details: Bank IBAN number, Credit card number (Only requested when you decide to purchase the service.)

Authentication, Security and Tracking Details: Turkish Republic Identification Number (TCKN)

Other Details: The company the person works for

Data Collected from Officials of Legal Entity Users:

Identification Details: Name,

Contact Details: E-mail address, phone number, address details

Data Collected for Billing Information: Name surname, Commercial Title, Turkish Republic Identity Number, Tax Number, Address Information, Phone Number, E-mail Address

Third Party Data: Third party personal data belonging to any third party account shared in relation to the Service during the Service utilized through the Site, e.g. e-mail address, any user name, etc.

Other Data -** Special Categories of Personal Data:** Special categories of personal data are defined by the Personal Data Protection Authority as "data that, if learned, may cause discrimination or grievance about the person concerned". The Company does not process the special categories of personal data of its Users.

Data Processed through Cookies: You can access detailed information regarding your processed data, primarily the logged-in IP Address, the device type used, the operating system, and browser details, from the "Cookie Policy" published on the Site. Pursuant to Articles 3 and 7 of the Law, data that has been irreversibly anonymized will not be considered personal data in accordance with the Law, and processing activities regarding this data will be carried out without being bound by the provisions of this Policy.

The User undertakes that their information subject to this Policy is complete, accurate, and up-to-date, and that in the event of any changes to this information, they will immediately update it. The Company shall not have any liability arising from the User's failure to share their current information.

Which of the Collected Data Will We Anonymize?

Anonymization of data means preventing the identification of individuals or losing the feature of being distinguishable within certain groups in a way that cannot be associated with a natural person. In this context, your data used by being anonymized are (i) the login times of Users and Visitors using the Site, (ii) the products they review and their features, (iii) the frequency of using the Site and purchasing services, (iv) data on which city the Users access the Site from or purchase services from, (v) information about the countries searched on the Site and the frequency of searches from these countries.

For Which Purposes Do We Process Your Data?

The Company may share personal data collected from officials of legal entity Users with preferred third-party companies for the execution of the necessary logistics operations within the scope of the performance of the Services. The Company may process personal data provided by the Users and new data generated by the Company using this personal data for the purposes of enabling the Users to benefit from the Site uninterruptedly, carrying out the necessary operational process during the provision of the service (enabling Users to log in to the Site without losing time and receive Services, listing and viewing companies they will receive Services from and reach via the Site, eliminating communication errors between the User and the company they decide to receive services from, etc.), providing and improving the services subject to the Site, ensuring the User's data security, managing relationship management processes with Users, ensuring coordination between the Company's units for the continuity of Services, keeping Visitor records, informing Users and Visitors about marketing activities to be made to keep them aware of promotions and advantages, generating statistical data from Visitor data, fulfilling the Company's obligations arising from laws and regulations, and preventing current or future legal disputes.

Regarding Cookies

The Company will be able to obtain information about Users' use of the Site by using cookies, which are technical communication files, process data in this context, and transmit them to third parties to be used only to the extent required by these analysis services, so that they can be processed within the scope of analysis services provided by third parties. The mentioned technical communication files are small text files that the Site sends to the browser of Users to be stored in the main memory. The technical communication file facilitates the use of the internet in this sense by storing status and preference settings about a website. The technical communication file is designed to obtain statistical information about how many people use the Site temporally, for what purpose, how many times a person visits the Site and how long they stay, and to help generate dynamic advertisements and content from user pages specially designed for Users, and is used for these purposes. The technical communication file is not designed to retrieve any other personal data from the main memory. Most browsers are initially designed to accept the technical communication file, but if Users wish, they can always change their browser settings so that the technical communication file does not arrive or a warning is given when the technical communication file is sent. You can find details about cookies in the "Cookie Policy" on the Site. In order to identify system-related problems and resolve problems urgently, the Company will be able to detect and use the IP address of Users when necessary. IP addresses can also be used to generally identify Users and gather broad demographic information.

Legal Ground for Data Collection

The main reason for collecting the data in question is the obligations in the relevant legislation. Additionally, we collect the personal data classified above due to the contractual relationship between us and the Users, our legitimate interests, and the commercial principles we adopt.

Who Can Access Your Data?

The Company shares the personal data provided by Users and Visitors and the new data generated by the Company using this personal data with the company reached through the Site that will perform the service the User wants to receive from the Site, in order to perform and/or develop the Services, improve the Users' experience, and realize any of the purposes specified under the heading "For Which Purposes Do We Process Your Data?" of this Policy, so that the service operation can be carried out.

The Company may also process the data subject to this Policy without obtaining further consent from Users and share it with third parties, in accordance with Articles 5 and 8 of the Law and/or in the presence of exceptions in the relevant legislation. The main ones of these situations are specified below:

It is explicitly provided for in the laws, It is mandatory for the protection of the life or physical integrity of the person or someone else, who is unable to express their consent due to actual impossibility or whose consent is not legally valid, Processing of personal data belongs is necessary, provided that it is directly related to the establishment or performance of a contract, including the Agreement, It is mandatory for the Company to fulfill its legal obligation, It has been made public by the Users themselves, Data processing is mandatory for the establishment, exercise or protection of a right, Data processing is mandatory for the legitimate interests of the Company, provided that it does not harm the fundamental rights and freedoms of the Users. The Company, limited to the fulfillment of the purposes mentioned above, shall only transfer the personal data it collects to receive data hosting services to:

In cases where your explicit consent is present, situations envisaged in the Law exist and there is adequate protection in the country to which the data is to be transferred, and situations envisaged in the Law exist and despite the lack of adequate protection in the country to be transferred, sufficient protection is committed in writing by the data controller in the relevant country and the Personal Data Protection Board ("Board") also has permission, the Company shall have the right to transfer to service-providing companies abroad (which may belong to itself, its group companies, subcontractors or internationally proven reliable service providers).

NOTICE TO USERS:

The User themselves are responsible for the data willingly provided to third parties, and the Company has no responsibility whatsoever in such sharing.

Regarding Your Right to Access Your Data and Your Correction Requests

Users have the right to apply to the Company and, regarding themselves;

Learn whether personal data is processed, Learn whether personal data is processed, Learn the purpose of processing personal data and whether they are used in accordance with their purpose, Know the third parties to whom personal data is transferred domestically or abroad, Request correction of personal data in case of incomplete or incorrect processing, Request correction of personal data in case of incomplete or incorrect processing, Request the deletion or destruction of personal data within the framework of the conditions provided for in the relevant legislation, Request notification of the operations of correction, deletion, and destruction made pursuant to the relevant legislation to third parties to whom personal data has been transferred, Object to the occurrence of a result against the person themselves by analyzing the processed data exclusively through automated systems, Demand the compensation of the damage in case of loss due to unlawful processing of personal data. Users will be able to exercise their statutory right of application, which they can use in line with their requests specified above, pursuant to Article 13, Paragraph 1 of the Law and other relevant legislation provisions, by transmitting it via one of the methods specified below or other methods to be determined by the Personal Data Protection Board. The current methods specified in the Law are as follows:

Filling out and wet-signing the Application Form Pursuant to the Law on the Protection of Personal Data ("Application Form") found on the Site, and then delivering it to the Company's headquarters at Sanayi Mah. Teknopark Bulvarı Teknopark 4A Apt. No: 1/4A/101 Pendik/ Istanbul (by the applicant coming in person with an identity encouraging document and delivering it by hand). After filling out the Application Form and signing it with a "secure electronic signature" defined in the Electronic Signature Law No. 5070, sending the secure electronically signed form to the "info@navlungo.com" e-mail address (the subject line of the e-mail shall read "Law on the Protection of Personal Data Information Request"). After filling out and wet-signing the Application Form, sending it to the Company's headquarters at Sanayi Mah. Teknopark Bulvarı Teknopark 4A Apt. No: 1/4A/101 Pendik/ Istanbul via a notary public (the notification envelope shall read "Information Request under the Law on the Protection of Personal Data"). For a person other than the applicant themselves to make a request, there must be a special power of attorney issued by the personal data owner on behalf of the person who will apply, regarding the subject.

Retention Period of Personal Data

The Company will act in accordance with the provisions of Law No. 6698 and the Regulation on the Deletion, Destruction or Anonymization of Personal Data ("Regulation"). In order for Users to benefit from the Site and Services, the Company will retain the personal data provided by Users for 10 years from the last day the Service was provided to them, for the purpose of fulfilling the obligations arising from the nature of the Services specified in this Policy, and from the date the communication permissions are removed for the data collected from Visitors, and will destroy the personal data in the first periodic destruction process following the date when the obligation to destroy personal data arises pursuant to the Regulation. The Company will properly fulfill its obligations arising from Article 12 of the Regulation against Users who request the destruction of their personal data based on Article 13 of the Law.

Our Measures and Commitments Regarding Data Security

The Company, under the conditions determined in the relevant legislation or expressed in this Policy, regarding the data transmitted to it electronically over the Site,

Undertakes to take the necessary technical and administrative measures and to have the necessary audits conducted in order to prevent unlawful processing of personal data, to prevent unlawful access to personal data, and to ensure the appropriate security level to maintain personal data. The Company cannot disclose personal data obtained about Users to others in violation of the provisions of this Policy and Law No. 6698, and will not use it other than for the purpose of processing. In the event of linking to other applications via the Site, the Company will not bear any responsibility for the privacy policies and contents of the applications.

Communication Permission

You have consented to the collection, storage, processing, use, and transfer of your personal data, which is specified in this Policy and which you have consented to share with us through electronic communication permission, with the purpose of providing and presenting various advantages to you and performing all kinds of electronic communications for customized advertisements, sales, marketing, surveys, reservation privileges and similar purposes, and sending other communication messages. The Company will contact Users via mail for verification of e-mail address during registration, verification that they are the correct person when password is forgotten, website creation, advertising over the website, sharing of the website, etc., making notifications for security reasons, and transmitting e-invoices; and via phone or SMS for verification of phone number during registration, making notification as a two-factor authentication method, verification that they are the correct person when they forget their password, and making notifications to be made for security reasons. The Company will take all necessary measures for the safe storage of such personal data, prevention of unauthorized access, and prevention of illegal data processing, in accordance with Article 12 of the Law.

Privacy of Users Regarding Age Limit

The Company will not intentionally collect and record the data of persons under the age of 18. If you are under the age of 18, we importantly inform you that you should not use the Platform and Services and should not share any of your personal data with the Company. The Company will take reasonable steps to delete the data upon learning that data of a person under the age of 18 has been collected.

Changes in the Policy

The Company may change the provisions of this Policy at any time by publishing them on the Site. The Policy provisions modified by the Company will become effective on the date they are published. The Company will make the necessary notifications to Users so that they are aware of the changes made in this Policy.

Dispute Resolution

This Policy is subject to the laws of the Republic of Turkey. All disputes arising from this Policy or related to this Agreement will be resolved in Istanbul Central (Çağlayan) courts and enforcement offices.

We would like to state that if this Policy is not approved by the Users, you cannot benefit from the Services.