Privacy Policy

We understand the importance of Personal Information and Non-Personal Information of our Users and are committed to ensuring the protection of such information in accordance with applicable data protection laws and regulations, including the Turkish Law on the Protection of Personal Data No. 6698 ("KVKK").

We collect, use, protect, store, share, transfer and disclose Personal Information and Non-Personal Information collected through Your access / usage of Our website domain under the name www.cda.com.tr and related mobile applications, including the CDA Lojistik mobile application available on Google Play (collectively referred to as "Platform").

This Privacy Policy ("Policy") is applicable to all logistics and transportation services being offered on the Platform by CDA Lojistik A.Ş. (CDA LOJİSTİK ANONİM ŞİRKETİ) (hereafter referred to as "Company", "CDA", "We", "Us" and/or "Our" as the context may require).

Reference of "You", "Your" or "User" in this Policy shall mean anyone who is availing Our Services by accessing Our Platform.

By accessing Our Platform, You are consenting to this Policy and the Terms and Conditions for availing the Services as available on the Platform and such other terms as may be reasonably required by Us from time to time to render the Services in an effective manner.

Collection of Personal Information and Non-Personal Information

When You use Our Platform for availing Our Services, We collect Your Personal Information and Non-Personal Information, provided by You during the course of Your access/use of Our Platform for availing Our Services.

In this Policy, Personal Information shall mean and include the following information:

• Your full name;
• Name of the company or organization (if any);
• Your current or previous addresses and company's or organization's address (if any);
• Your e-mail address;
• Your mobile phone number and/or telephone number;
• Your User ID and password;
• Information on Your shipments, such as bill of lading (B/L) numbers, container numbers, booking and voyage details, cargo type and shipment status;
• Invoice, billing and financial information related to Your transportation transactions with Us;
• Messages, files, documents, images, audio recordings and other content You share through the in-app chat and document features;
• Your location data, collected and used by the CDA Lojistik app for the proper functioning of the business and these apps (for example, to display nearby offices and on map features);
• Information from Your device, such as device model, operating system and a push-notification (FCM) token used to deliver notifications;
• Other information provided when You correspond with Us through Our Platform; and
• Any updates to the information provided by You to Us.

Other than the Personal Information, the following Non-Personal Information is collected:

• Technical information collected from the Platform like internet protocol (IP) address, device type, operating system, and date or time stamp of the User accessing the Platform;
• Usage information and in-app activity logs (such as which screens are accessed) used to operate, secure and improve the Platform;
• Information collected through cookies, beacons and other digital markers while navigating or accessing Our Platform;
• Your response to Our emails, offers or links sent by Us; and
• All the details that may be requested by Us while any User visits, accesses or uses Our Platform.

We may also collect, store, manage and process certain Personal Information and Non-Personal Information provided by You to avail and use the services of third parties offered on Our Platform.

We shall ensure that Your Personal Information is updated once filled in by You; however, in case of any change or discrepancy in Your Personal Information, You shall intimate the same to Us through the contact details provided in this Policy.

Use of Personal Information and Non-Personal Information

We will use Your Personal Information and Non-Personal Information for the following purposes:

• To render/handle the Services that You or Your company or organization have requested;
• To implement transactions You requested and, more generally, to provide You with the Services and information requested from Us, including to respond to inquiries about the tracking of shipments or ensuring adequate pick-up and delivery of cargo;
• To resolve Your claims, including for any cargo damage;
• To respond to the inquiries We receive from You or Your company or organization;
• To send You operational notifications and updates about Your shipments and account via push notifications, e-mail or in-app messaging;
• To provide You notices of Our products, services and service developments, as well as personalized content that may address Your needs;
• To track the trend, User movement and use of the Platform by the User;
• To identify problems in the Platform and enhance the User experience;
• For authentication and identification purposes;
• For audit and reporting purposes, to perform accounting and administrative tasks and to enforce or manage legal claims;
• For internal review and analytical purposes;
• To improve the security of Our Platform and train Our customer-facing staff;
• To comply with Our legal obligations under applicable law, including the KVKK;
• To use Your location data within the CDA Lojistik app for the proper functioning of the business and these apps;
• To protect, enforce or defend legal rights, privacy, safety or property, whether Our own or that of Our directors, employees, officers, members or others, and to enforce compliance with this Policy, comply with applicable law or government requests, or resolve any disputes in relation to the Services provided by Us to You;
• We retain uploaded images, videos, audio or document files as necessary to resolve disputes, provide customer support, troubleshoot problems, or for internal research and analysis as permitted by law.

The Personal Information and Non-Personal Information collected shall be retained by Us for as long as it takes to fulfill the purposes stated above or as otherwise required under applicable laws.

Permission for Collection of Personal Information and Non-Personal Information

You can visit most areas of the Platform without providing Us any information; however, to avail Our Services Our Platform requires Personal Information and Non-Personal Information from You. Such information is required to fulfill Our legitimate interest of knowing You as a user of Our Platform or to offer You the Services that fulfill Your needs. The provision of Your Personal Information and Non-Personal Information is voluntary and is therefore based on Your consent. However, if You do not provide such information or decide to opt-out or withdraw the consent for collection, storage and usage of the Personal Information and Non-Personal Information, You may not be able to avail Our Services through Our Platform, and We reserve the right to suspend Your access to the account and Platform.

Device Permissions

To provide certain features, the CDA Lojistik mobile application may request the following device permissions. You may grant or revoke these permissions at any time through Your device settings; revoking a permission may disable the related feature:

• Location – to show nearby offices, map locations and location-based shipment features;
• Camera – to take and attach photos within the app (for example, to documents or chat);
• Photos / Storage / Files – to attach, upload, download and view documents and images;
• Microphone – to record and send voice messages in the in-app chat;
• Notifications – to deliver push notifications about shipments, messages and account activity.

Sharing of Personal Information and Non-Personal Information

We may disclose and/or share Your Personal Information and Non-Personal Information collected and stored by Us in the following manner and circumstances, to which You consent as and when You agree to avail Our Services:

• With any company that is a member of Our group of companies / Our affiliates, where it is in Our legitimate interest to do so for internal administrative purposes and to perform the Services in an efficient manner as requested by You through the Platform;
• With third-party service providers (such as hosting, cloud, push-notification and infrastructure providers, including Google Firebase Cloud Messaging) as may be required for Us to: (a) provide access to Our Platform for rendering of Services; (b) conform with applicable legal obligations; (c) enforce Our Policy, Terms and Conditions and other agreements (if any); (d) carry out Our advertising and marketing activities; or (e) detect and prevent fraudulent or illegal activities;
• With government authorities or where required under applicable laws or in the good-faith belief that such disclosure is reasonably necessary to respond to law firms, auditors, consultants, police, subpoenas, courts, tribunals or any other legal processes in relation to the Services provided to You by Us;
• With another entity involved in the case of a scheme of merger, acquisition, re-organization, amalgamation or any other restructuring of Our business. In case of such a scheme being approved, the other business entity or the new combined entity will follow this Policy or such amendments as considered appropriate and conveyed to You.

Your consent for sharing of Your Personal Information and Non-Personal Information is obtained through click-through agreements or where Your consent is part of the Terms and Conditions agreed upon by You for availing Our Services.

Users' Rights in Relation to Submitted Personal Information and Non-Personal Information

In relation to the submitted Personal Information and Non-Personal Information, and in accordance with the KVKK, Users are entitled to:

• request access to and information about Your Personal Information and Non-Personal Information processed by Us;
• request an opt-out and withdraw the consent given for the use of Your Personal Information and Non-Personal Information;
• request the rectification of Your Personal Information and Non-Personal Information;
• request the deletion or destruction of Your Personal Information, subject to applicable legal retention obligations;
• in case of any feedback, concerns, questions, discrepancies or grievances, lodge a complaint with Us using the contact details specified here-under below.

You may also request the deletion of Your account and associated data by contacting Us at [email protected]. The above-mentioned requests by You may take up to several days to implement.

Security Precautions

We have adopted and placed various security practices and procedures including technical, operational, managerial and physical security controls to safeguard Your Personal Information and Non-Personal Information and to protect against the loss, misuse and any alteration of the information under Our control. Communication between the application and Our servers is protected using industry-standard encryption (HTTPS/TLS). Further, Our directors, officers, employees or members are bound by a confidentiality policy which mandates and obligates them to protect the confidentiality of Personal Information and Non-Personal Information. We also conduct audits of Our security practices and procedures in accordance with applicable laws.

While sharing Your Personal Information and Non-Personal Information as specified above, appropriate measures shall be taken to ensure that the same level of security practices and procedures are followed by such third parties.

Whenever You access Your account using Your user ID and password, We offer You a secure server. Although We take such steps to protect Your Personal Information and Non-Personal Information, no security practice and procedure is foolproof, and thus We cannot guarantee the absolute security of Your Personal Information and Non-Personal Information.

Cookies

Cookies, beacons and digital markers are small computer files that may be stored on Your computer's hard drive and/or embedded in Our Platform page that enable Us to identify You and track Your visit on the Platform. You may disable cookies on Your computer and/or mobile device by changing the settings in the preferences/options menu in Your browser if You do not wish to disclose such surfing information; however, disabling cookies, beacons and digital markers may affect the overall User experience of the Platform.

Collection of Information from Children

The Services shall not be rendered to anyone under the age of 18 (eighteen) years, unless the consent of their parents/legal guardian is obtained. We do not knowingly collect Personal Information from anyone under the age of 18 (eighteen) years and recommend that anyone under the age of 18 (eighteen) years seek Our Services through their parents/legal guardian, or shall seek permission of their parents/legal guardian before accessing/using Our Platform.

External Links

Our Platform contains links to other websites that We do not own or operate. We provide such third-party website links for Your convenience and for Our members. These third-party website links are neither an endorsement nor a referral to such linked services. Further, such third-party website links are subject to their separate and independent privacy policies, practices, procedures, statements, notices, terms and conditions, which We recommend You read carefully. The collection, use, and disclosure of Your Personal Information and Non-Personal Information will be subject to the privacy policies, procedures and practices of such third parties.

Amendments

This Policy is subject to change, alteration or modification from time to time, for which it shall be updated and posted with such changes on the Platform. Therefore, a periodic review of the Policy from Your end is recommended to keep You updated with the changes, alterations and modifications incorporated in the Policy.

Governing Law and Dispute Resolution

This Policy shall be governed by and construed in accordance with the laws of the Republic of Turkey. All disputes in relation to this Policy shall be adjudicated exclusively by/before the competent courts and execution offices of Istanbul (Anadolu), Turkey.