Protection of Personal Data

ARAS KARGO YURT İÇİ YURT DIŞI TAŞIMACILIK ANONİM ŞİRKETİ
PRIVACY NOTICE ON SHIPMENT ACCEPTANCE, CARRIAGE AND DELIVERY PROCESSES

1.Data Controller

Aras Kargo Yurt İçi Yurt Dışı Taşımacılık Anonim Şirketi Rüzgarlıbahçe Mah. Yavuz Selim Cad. No:2 Beykoz / İstanbul

Aras Kargo Yurt İçi ve Yurt Dışı Taşımacılık A.Ş. (“Aras Kargo” or the “Company”) respects your rights regarding your privacy and the protection of your personal data. Accordingly, our Company adopts all technical and administrative measures in order to ensure the security of your data and thereby ensures high standards of protection for your personal data.

Our Company operates as a postal service provider pursuant to the Regulation on the Provision of Postal Services, which was published in the Official Gazette No. 29019 of June 3, 2014, and in accordance with all applicable legislation, including the Law No. 6475, the decisions of the Information and Communication Technologies Authority (“ICTA”) - particularly the ICT’s decision no. 2016/DK-YED/517 of December 27, 2016 regarding the Procedures and Principles on Security Measures for Postal Shipments, the Road Transport Act No. 4925 and the Road Transport Regulation.

Within this scope, this Privacy Notice on Shipment Acceptance, Carriage and Delivery Processes (the “Privacy Notice”) is intended to provide clarifications, in our capacity as the data controller, to your party on the categories of personal data which are processed, the methods of and legal bases for the collection of your personal data, the purpose(s) for transfer and the recipient(s) of your personal data, and the exercise of your rights under article 11 of the LPPD, pursuant to article 10 of the Law No. 5598 on the Protection of Personal Data (“LPPD”) and the Communiqué on the Procedures and Principles to be Followed for the Fulfillment of the Obligation to Inform, in relation to the shipment acceptance, carriage and delivery processes concerning the postal services which are provided.

2.The Methods of Collection of Your Personal Data

Your personal data which are limited to the categories listed in the charts below may be collected by Aras Kargo wholly or partly by automated means or provided that the process is a part of any data filing system, through non-automated means, from physical and/or electronic environments, via our Company’s websites and mobile applications, printed forms (agreements, shipment request forms, documents substantiating the provision of services), shippers, call center, e-mail, phone, SMS, facsimile, parcel/mail, request / complaint / suggestion platforms, online meeting platforms, Company headquarters, regional directorates, branches, agencies and all units affiliated to our Company, our suppliers, business partners and intermediary parcel/courier companies, internal information technology systems and integrated systems pertaining to authorized public institutions and organizations and other related 3rd parties.

3.The Categories of Your Processed Personal Data and the Purposes for and the Legal Basis of the Processing of Your Personal Data

The purposes for and the legal basis of the processing and transfer of your personal data which are limited to the personal data categories that are collected within the scope of the shipment acceptance, carriage and delivery processes are detailed in the charts below for each data subject category:

A.Shippers(Individual or Corporate)

The following information pertaining to the shippers are processed by our Company for the purposes and legal bases stated in the chart when shipments are submitted to Aras Kargo for carriage:

Data CategoryLegal BasisPurpose for Processing
Identification
Contact Details
Customer Transaction
  • being expressly permitted by law, as stipulated in art. 5(2)(a) of the LPPD;
  • the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in art. 5(2)(c) of the LPPD;
  • data processing being required for the data controller’s compliance with a legal obligation, as stipulated in art. 5(2)(ç) of the LPPD;
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Acceptance of shipments and creation of the shipment records;
Management of contract of carriage processes;
Conducting of carriage, distribution and delivery operations;
Conducting and ensuring the continuity of business activities;
Conducting of sales, finance and accounting transactions;
Conducting of communication activities;
Follow up of requests / complaints and conducting of customer relations and satisfaction management;
Ensuring the security of our Company’s operations and shipments;
Management of audits / internal audits;
Conducting of activities in accordance with the legislation;
Follow up of legal and compliance affairs;
Furnishing of information to authorized individuals, institutions and organizations;
Management of storage and archiving activities.
Finance*
  • being expressly permitted by law, as stipulated in art. 5(2)(a) of the LPPD;
  • the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in art. 5(2)(c) of the LPPD;
  • data processing being required for the data controller’s compliance with a legal obligation, as stipulated in art. 5(2)(ç) of the LPPD;
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Conducting of sales, finance and accounting transactions;
Follow up of requests / complaints and conducting of customer relations and satisfaction management;
Management of audits / internal audits;
Conducting of activities in accordance with the legislation;
Follow up of legal and compliance affairs;
Furnishing of information to authorized individuals, institutions and organizations;
Management of storage and archiving activities.
Legal Action*
  • data processing being required for the establishment, exercise or protection of a right, as stipulated in art. 5(2)(e) of the LPPD;
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Management of audits / internal audits;
Conducting of activities in accordance with the legislation;
Follow up of legal and compliance affairs;
Furnishing of information to authorized individuals, institutions and organizations;
Management of storage and archiving activities.

* Finance data may only be processed if the shipment fee is paid by your party.

* Legal action data may only be processed if a legal dispute arises.

B.Senders(if different from Shippers)

The following information pertaining to the senders delivering the shipments to Aras Kargo (for the shippers) are processed by our Company for the purposes and legal bases stated in the chart due to shipments being passed to Aras Kargo by such persons:

Data CategoryLegal BasisPurpose for Processing
Identification
Contact Details
  • being expressly permitted by law, as stipulated in art. 5(2)(a) of the LPPD;
  • data processing being required for the data controller’s compliance with a legal obligation, as stipulated in art. 5(2)(ç) of the LPPD;
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Acceptance of shipments and creation of the shipment records;
Conducting of carriage, distribution and delivery operations;
Conducting and ensuring the continuity of business activities;
Conducting of sales, finance and accounting transactions;
Conducting of communication activities;
Follow up of requests / complaints and conducting of customer relations and satisfaction management;
Management of audits / internal audits;
Conducting of activities in accordance with the legislation;
Follow up of legal and compliance affairs;
Furnishing of information to authorized individuals, institutions and organizations;
Management of storage and archiving activities.
Legal Action*
  • data processing being required for the establishment, exercise or protection of a right, as stipulated in art. 5(2)(e) of the LPPD;
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Management of audits / internal audits;
Conducting of activities in accordance with the legislation;
Follow up of legal and compliance affairs;
Furnishing of information to authorized individuals, institutions and organizations;
Management of storage and archiving activities.

* Legal action data may only be processed if a legal dispute arises.

C.Employees/Officers/Representatives of Corporate Shippers

The following information pertaining to the natural persons authorized to send shipments with Aras Kargo on behalf of legal entities as their employees/officers/representatives are processed by our Company for the purposes and legal bases stated in the chart when shipments are sent by such persons:

Data CategoryLegal BasisPurpose for Processing
Identification
Contact Details
  • being expressly permitted by law, as stipulated in art. 5(2)(a) of the LPPD;
  • data processing being required for the data controller’s compliance with a legal obligation, as stipulated in art. 5(2)(ç) of the LPPD;
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Acceptance of shipments and creation of the shipment records;
Management of contract of carriage processes;
Conducting of carriage, distribution and delivery operations;
Conducting and ensuring the continuity of business activities;
Conducting of sales, finance and accounting transactions;
Conducting of communication activities;
Follow up of requests / complaints and conducting of customer relations and satisfaction management;
Ensuring the security of our Company’s operations and shipments;
Management of audits / internal audits;
Conducting of activities in accordance with the legislation;
Follow up of legal and compliance affairs;
Furnishing of information to authorized individuals, institutions and organizations;
Management of storage and archiving activities.
Legal Action*
  • data processing being required for the establishment, exercise or protection of a right, as stipulated in art. 5(2)(e) of the LPPD;
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Management of audits / internal audits;
Conducting of activities in accordance with the legislation;
Follow up of legal and compliance affairs;
Furnishing of information to authorized individuals, institutions and organizations;
Management of storage and archiving activities.

* Legal action data may only be processed if a legal dispute arises.

D.Consignees

The following information pertaining to the persons receiving shipments through Aras Kargo and submitted to our Company by the shippers are processed by our Company for the purposes and legal bases stated in the chart when shipments are sent to such persons:

Data CategoryLegal BasisPurpose for Processing
Identification
Contact Details
Customer Transaction
  • being expressly permitted by law, as stipulated in art. 5(2)(a) of the LPPD;
  • data processing being required for the data controller’s compliance with a legal obligation, as stipulated in art. 5(2)(ç) of the LPPD;
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Acceptance of shipments and creation of the shipment records;
Management of contract of carriage processes;
Conducting of carriage, distribution and delivery operations;
Conducting and ensuring the continuity of business activities;
Conducting of sales, finance and accounting transactions;
Conducting of communication activities;
Follow up of requests / complaints and conducting of customer relations and satisfaction management;
Ensuring the security of our Company’s operations and shipments;
Management of audits / internal audits;
Conducting of activities in accordance with the legislation;
Follow up of legal and compliance affairs;
Furnishing of information to authorized individuals, institutions and organizations;
Management of storage and archiving activities.
Visual Recording*
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Conducting of carriage, distribution and delivery operations;
Follow up of requests / complaints and conducting of customer relations and satisfaction management;
Ensuring the security of our Company’s operations and shipments;
Management of audits / internal audits;
Management of storage and archiving activities.
Finance*
  • being expressly permitted by law, as stipulated in art. 5(2)(a) of the LPPD;
  • data processing being required for the data controller’s compliance with a legal obligation, as stipulated in art. 5(2)(ç) of the LPPD;
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Conducting of sales, finance and accounting transactions;
Follow up of requests / complaints and conducting of customer relations and satisfaction management;
Management of audits / internal audits;
Conducting of activities in accordance with the legislation;
Follow up of legal and compliance affairs;
Furnishing of information to authorized individuals, institutions and organizations;
Management of storage and archiving activities.
Legal Action*
  • data processing being required for the establishment, exercise or protection of a right, as stipulated in art. 5(2)(e) of the LPPD;
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Management of audits / internal audits;
Conducting of activities in accordance with the legislation;
Follow up of legal and compliance affairs;
Furnishing of information to authorized individuals, institutions and organizations;
Management of storage and archiving activities.

* Visual recording data may only be processed in cases where the consignees are not at the address and the photographs of delivery address are taken as proof of visit.

* Finance data may only be processed if the shipment fee is paid by your party.

* Legal action data may only be processed if a legal dispute arises.

4.Recipients(if different from Consignees)

The following information pertaining to the recipients receiving the shipments from Aras Kargo (for the consignees) are processed by our Company for the purposes and legal bases stated in the chart due to shipments being received from Aras Kargo by such persons:

Data CategoryLegal BasisPurpose for Processing
Identification
Customer Transaction
  • being expressly permitted by law, as stipulated in art. 5(2)(a) of the LPPD;
  • data processing being required for the data controller’s compliance with a legal obligation, as stipulated in art. 5(2)(ç) of the LPPD;
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Acceptance of shipments and creation of the shipment records;
Conducting of carriage, distribution and delivery operations;
Conducting and ensuring the continuity of business activities;
Conducting of sales, finance and accounting transactions;
Conducting of communication activities;
Follow up of requests / complaints and conducting of customer relations and satisfaction management;
Ensuring the security of our Company’s operations and shipments;
Management of audits / internal audits;
Conducting of activities in accordance with the legislation;
Follow up of legal and compliance affairs;
Furnishing of information to authorized individuals, institutions and organizations;
Management of storage and archiving activities.
Legal Action*
  • data processing being required for the establishment, exercise or protection of a right, as stipulated in art. 5(2)(e) of the LPPD;
  • data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in art. 5(2)(f) of the LPPD
Management of audits / internal audits;
Conducting of activities in accordance with the legislation;
Follow up of legal and compliance affairs;
Furnishing of information to authorized individuals, institutions and organizations;
Management of storage and archiving activities.

* Legal action data may only be processed if a legal dispute arises.

5.The Transfer of Your Personal Data

Your personal data which are processed within the scope of the shipment acceptance, carriage and delivery processes may be transferred to the following recipient groups in cases where the conditions for transfer which are regulated in articles 8 and/or 9 of the LPPD are satisfied:

RecipientsData CategoriesPurpose for Transfer
Our Suppliers(parties providing products and services to our Company in information technology, accounting, legal processes, archiving etc.)Identification
Contact Details
Customer Transaction
Finance
Legal Action
for the purposes as specified hereinabove for each data category, and particularly, in order to ensure the rendering of our services and the conducting of our corporate activities
Shippers, consignees, recipientsIdentification
Contact Details
Customer Transaction
for the purposes as specified hereinabove for each data category, and particularly, in order to ensure the conducting of the carriage operation, the tracking and delivery of the shipments and the security of shipments
Our Business Partners(Aras Kargo’s solution partners which act as intermediaries to the sale or provision of postal services or parties providing additional products, services and benefits for such processes)Identification
Contact Details
Customer Transaction
Finance
Legal Action
for the purposes as specified hereinabove for each data category, and particularly, in order to benefit from the opportunities offered by our business partners while rendering our services and conducting our corporate activities
Authorized public institutions and organizations(ICTA, courts, consumer arbitration committees)Identification
Contact Details
Customer Transaction
Finance
Legal Action		for the purposes as specified hereinabove for each data category, and particularly, in order to fulfill our statutory obligations and the establishment, exercise and protection of our rights in case of any dispute
6.Your Rights as Data Subject

Your rights as a data subject are stipulated in article 11 of the LPPD, and you may communicate your application to exercise your rights, to our Company, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller.

As a data subject, you may adhere to the instructions provided in the 'Roadmap for Application to the Data Controller' to guide you through the application process.

N.B.: Please note that no special categories of personal data (e.g. religion or blood type information) should be included in the said documentation.