Privacy Policy

Genel Denizcilik Nakliyatı ve Ticaret A.Ş. (“GEDEN”, “we”, “us”, “our”) Büyükdere Cad. Yapı Kredi Plaza A Blok Kat:12, Levent 34330, Beşiktaş, İstanbul, Türkiye Email: info@geden.com | Phone: +90 (212) 319 51 00

Last updated: 08.09.2026

1. Introduction

GEDEN respects your privacy and is committed to protecting the personal data of visitors to our website (the “Site“), as well as our customers, business partners, job applicants, and other individuals whose personal data we process in the course of our shipping, chartering, and maritime trade activities.

This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have, in accordance with Turkey’s Law on the Protection of Personal Data No. 6698 (“KVKK”) and, where applicable, the EU General Data Protection Regulation (“GDPR”) for visitors located in the European Economic Area.

GEDEN acts as the data controller (veri sorumlusu) for the personal data described in this Policy.

2. Personal Data We Collect

Depending on how you interact with us, we may collect:

  • Identity and contact data: name, surname, job title, company name, email address, phone number, mailing address.
  • Communication data: messages you send us through contact forms, email correspondence, and records of our replies.
  • Business and commercial data: information provided in connection with chartering, cargo, freight, or other maritime trade inquiries and contracts.
  • Job application data: CVs, cover letters, references, and other information submitted for recruitment purposes.
  • Technical data: IP address, browser type, device information, pages visited, and access times, collected automatically via cookies and similar technologies.
  • Cookie and usage data: as described in Section 7 below.

We do not knowingly collect special categories of personal data (e.g., health, religion, biometric data) through the Site unless voluntarily provided by you (for example, in a CV) and strictly necessary for the stated purpose.

3. How We Collect Personal Data

We collect personal data:

  • Directly from you, when you fill in a contact or inquiry form, send us an email, apply for a job, or otherwise communicate with us;
  • Automatically, through cookies and similar tracking technologies when you browse the Site;
  • From third parties, such as business partners, agents, or publicly available sources, in connection with our commercial shipping activities.

4. Purposes of Processing

We process your personal data for the following purposes:

  • Responding to inquiries submitted through the Site or by email/phone;
  • Managing and performing chartering, freight, and other commercial/maritime trade relationships;
  • Evaluating job applications and managing recruitment processes;
  • Operating, maintaining, and improving the Site, including troubleshooting and security;
  • Analyzing Site usage to improve user experience;
  • Complying with legal, regulatory, tax, and maritime industry obligations;
  • Establishing, exercising, or defending legal claims;
  • Corporate communications with business partners, agents, and stakeholders.

5. Legal Basis for Processing (KVKK Article 5 / GDPR Article 6)

We process personal data on one or more of the following legal bases:

  • Your explicit consent, where required (e.g., certain cookies, unsolicited job applications);
  • Performance of a contract to which you are a party, or steps taken at your request prior to entering into a contract;
  • Compliance with a legal obligation to which GEDEN is subject;
  • Our legitimate interests, such as operating and securing the Site, responding to business inquiries, and managing recruitment, provided these interests do not override your fundamental rights and freedoms.

6. Sharing and Transfer of Personal Data

We may share your personal data with:

  • Group companies and affiliates of GEDEN, where necessary for our shipping and trade operations;
  • Business partners, agents, port authorities, and counterparties involved in the relevant chartering or trade transaction;
  • Service providers who support our IT systems, hosting, and Site operations, acting under confidentiality obligations;
  • Legal, financial, and regulatory advisors, courts, and public authorities, where required by law or to protect our legal rights;
  • Competent authorities, where disclosure is necessary for compliance with applicable laws and regulations.

Given the international nature of our maritime business, personal data may be transferred outside Türkiye, including to countries that may not have an equivalent level of data protection. Where such transfers occur, we take appropriate measures required under KVKK (including, where applicable, explicit consent or other legal grounds recognized by the Turkish Personal Data Protection Board) and, where relevant, GDPR-compliant safeguards such as Standard Contractual Clauses.

7. Cookies and Similar Technologies

Our Site may use cookies and similar technologies to:

  • Ensure the Site functions properly;
  • Remember your preferences;
  • Analyze Site traffic and usage patterns.

You can control or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Site.

You can view our cookie policy here.

 

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including to satisfy any legal, accounting, or reporting requirements. Retention periods vary depending on the type of data and the purpose of processing (e.g., commercial correspondence, recruitment records, contractual documentation) and are determined in line with applicable Turkish legislation, including commercial and tax record-keeping obligations.

Unsuccessful job applications and related data are retained only for a limited period unless you consent to a longer retention for consideration of future opportunities.

9. Data Security

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or destruction. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

10. Your Rights

Under KVKK Article 11, you have the right to:

  • Learn whether your personal data is being processed;
  • Request information about the processing, if your data has been processed;
  • Learn the purpose of processing and whether your data is used in accordance with that purpose;
  • Know the third parties to whom your data is transferred, domestically or abroad;
  • Request correction of incomplete or inaccurate data;
  • Request deletion or destruction of your data, subject to legal conditions;
  • Request that any correction, deletion, or destruction be notified to third parties to whom your data was transferred;
  • Object to a result that is to your detriment arising from automated processing of your data;
  • Claim compensation for damages arising from unlawful processing of your data.

If you are located in the European Economic Area, you may also have additional rights under the GDPR, including the right to data portability and the right to lodge a complaint with a supervisory authority.

To exercise your rights, you may contact us using the details in Section 11 below, or submit a written request in accordance with the procedures set out by the Turkish Personal Data Protection Authority (KVKK).

11. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact:

Genel Denizcilik Nakliyatı ve Ticaret A.Ş. Büyükdere Cad. Yapı Kredi Plaza A Blok Kat:12, Levent 34330, Beşiktaş, İstanbul, Türkiye Email: info@geden.com Phone: +90 (212) 319 51 00

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The updated version will be posted on this page with a revised “Last updated” date. We encourage you to review this Policy periodically.