Legal documents

LAST UPDATED: 4 OCTOBER 2026

English translation

This is an English translation provided for convenience. The Turkish version is the legally binding text and prevails in case of any discrepancy.

These documents have not yet completed legal review

They were written to match how the service actually works, but have not yet been approved by legal counsel. Fields in [square brackets] will be completed and this notice removed once the review is finished.

CONTENTS

  1. Privacy Notice (KVKK)
  2. Privacy Policy
  3. Terms of Use
  4. Pre-Contract Information and Distance Service Sales Agreement
  5. Payment, Cancellation and Refund Terms
  6. Information Security Policy
  7. Data Processing Terms
  8. Cookie Policy

1. Privacy Notice (KVKK)

Prepared under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK").

Data controller

Navluno. Contact: info@navluno.com

For data that customers enter into the platform themselves (for example, contact details of carrier representatives), the customer is the data controller and Navluno is the data processor (see Data Processing Terms).

Personal data processed

Data subjectData processed
Customer representative purchasing a planName, email, phone; for invoicing: company title, tax office, tax number or Turkish ID number, address; order record; contract acceptance record (date, time, IP address, browser information). Card details are not processed by Navluno; they are entered on the payment institution's page.
Platform user (customer employee)Name, username, email address, role, password hash (bcrypt), two-step verification data, session and sign-in attempt records, activity logs
Carrier (forwarder) representativeCompany name, representative's email address, quote content and quote link usage record
Person opening a trial workspaceCompany name, name, business email, IP address, sign-up time
Website visitorStrictly necessary cookies (see Cookie Policy); the content of any email you send us

Purposes and legal grounds

Transfers

RecipientPurposeLocation
Railway Corp.Hosting the application and dataAbroad (EU – Netherlands; Railway Corp. is a US company)
Sendinblue SAS (Brevo)Sending invitation, notification, sign-in and receipt emailsAbroad (EU)
iyzico Ödeme Hizmetleri A.Ş.Taking card payments; only buyer name, email, phone, billing address and order amount are sharedTurkey
E-invoice provider and accountantIssuing invoices and accounting obligationsTurkey
Competent public authoritiesWhere legally required, upon requestTurkey

Transfers to providers abroad fall under Article 9 of the KVKK and are made under standard contracts [signing of the standard contracts and notification to the Board to be completed with legal counsel]. Beyond these, data is not transferred to third parties, sold, or used for advertising or profiling.

Collection method

Data is collected electronically and by automated means, from the information the data subject enters on the purchase, sign-up and application screens and from records created while using the platform.

Retention periods

When the period ends, the data is deleted, destroyed or anonymised.

Your rights

Under Article 11 of the KVKK you have the right to learn whether your personal data is processed; to request information about it; to learn the purpose of processing and whether it is used accordingly; to know the third parties in Turkey or abroad to whom it is transferred; to request correction if it is incomplete or inaccurate; to request its deletion or destruction; to request that these actions be notified to third parties to whom the data was transferred; to object to a result against you arising solely from automated analysis; and to claim compensation for damage caused by unlawful processing.

You can send requests to info@navluno.com. Requests are answered free of charge within thirty days at the latest.

2. Privacy Policy

Navluno is an online business software service (SaaS) for collecting spot freight requests and comparing quotes. This policy explains what data we process, why, and how we protect it.

What we collect

We collect only the data the service needs to work: account and billing details, freight request content, documents attached to requests, quotes submitted by carriers, and activity and security logs. We do not use ad networks, analytics software, tracking pixels or social media tracking code.

Each customer's data is separate

Each customer works in its own workspace: the application runs as a separate process for each customer and its data is kept in a separate data folder. One customer's users cannot see another customer's data. See the Information Security Policy for details.

Payment details

Card payments are made on the secure payment page of iyzico Ödeme Hizmetleri A.Ş. The card number, expiry date and security code never reach Navluno's servers and are not stored. We only record the result of the payment and the transaction number issued by the payment institution.

Email

Invitations to carriers and account notifications are sent through our sending infrastructure on a domain authenticated with SPF, DKIM and DMARC. In invitations, the sender name is the username of the customer user who performed the action, and replies go to the customer's email address.

Sub-processors

Any change to the list of sub-processors will be announced on this page.

You as the data owner

The customer organisation owns the data it enters into the platform. During the plan and within 90 days after it ends, you may request that your data be exported or deleted. Send requests to info@navluno.com.

3. Terms of Use

The service

Navluno is an online software service that lets users create spot freight requests, invite carriers to quote with a single link and compare the quotes received on one screen. Navluno does not provide transport services, is not a party to any contract of carriage and does not guarantee the accuracy of quotes.

Plans

Accounts

Use of email

User obligations

Suspension

In case of a serious breach of these terms, a security threat or misuse, access may be suspended until the breach is remedied. The reason is notified to the customer's email address.

Intellectual property

All rights in the software, interface design and promotional content belong to Navluno. The customer is granted a non-transferable, non-exclusive right of use for the duration of the plan only. Data the customer enters into the platform belongs to the customer.

Service level and liability

We aim to provide the service continuously, except for planned maintenance and outages caused by the infrastructure provider; uninterrupted operation is not guaranteed. Planned maintenance is done outside business hours where possible. Navluno is not liable for indirect damage, loss of profit, or the consequences of business decisions made in reliance on quotes provided by third parties. Except in cases of intent or gross negligence, liability is limited to the plan fees paid in the last twelve months.

End of the plan

The plan ends automatically at the end of the purchased term. Within 90 days after it ends, the data is delivered in machine-readable form on request; it is deleted at the end of this period.

Changes

If these terms change, the current text is published on this page and admins are notified by email. Fees already paid for the current term do not change.

Governing law

These terms are governed by Turkish law. The courts and enforcement offices of the Republic of Türkiye have jurisdiction over disputes (Turkish text: Türkiye Cumhuriyeti mahkemeleri ve icra daireleri).

4. Pre-Contract Information and Distance Service Sales Agreement

The sales agreement is concluded in Turkish. During purchase it is filled in automatically with your billing details, the selected plan and the amounts, and you accept it by ticking the box on the payment page; a copy of the completed agreement is emailed to you after payment.

The agreement covers, in summary: the parties and the service; plan, price and VAT; upfront payment by card through iyzico or by bank transfer; immediate start of the service on payment confirmation; no automatic renewal; the absence of a right of withdrawal for electronically provided services started immediately with the buyer's consent; refunds for failures attributable to Navluno; data protection; and jurisdiction. The full text is available in the Turkish version.

5. Payment, Cancellation and Refund Terms

6. Information Security Policy

The technical and organisational measures we apply to protect the confidentiality, integrity and availability of customer data. This policy also explains how the data security obligation under Article 12 of the KVKK is met.

Separation between customers

Access and authentication

Transmission and storage

Backup and continuity

Logging and monitoring

Development and change management

Staff and administrative access

Security breaches

If personal data is found to have been obtained by unauthorised persons, the affected customer is informed without delay and within 72 hours at the latest; the Personal Data Protection Board and, where necessary, the data subjects are notified under Article 12/5 of the KVKK. To report a vulnerability: info@navluno.com

Customer responsibility

Security is a shared responsibility. The customer is responsible for using strong passwords, enabling two-step verification, closing the accounts of departing employees and assigning user roles correctly.

7. Data Processing Terms

Under Article 12/2 of the KVKK, these are the terms between the customer ("Data Controller") and Navluno ("Data Processor") regarding personal data the customer enters into the platform. They form an integral part of the sales agreement.

Scope

Personal data the customer enters into or creates on the platform: account details of the customer's users, names and contact details of carrier representatives, personal data within request and quote content, and uploaded documents.

Processor obligations

Controller obligations

8. Cookie Policy

No advertising, analytics or profiling cookies are used. There are only cookies that are strictly necessary for the service to work.

CookiePurposeType and duration
Session cookieCarries the signed-in user's session. It contains a random session identifier, not personal data.Strictly necessary. Deleted when the browser is closed or the session ends.
Workspace routing cookie (nvl_deneme)Determines which customer workspace the browser is routed to. It contains the workspace code and a server signature.Strictly necessary. Up to 1 year.
Language preference (nvl_dil)Remembers whether you chose Turkish or English. It contains only "tr" or "en".Functional. Up to 1 year.

As strictly necessary cookies do not require consent, no cookie banner is shown. If you block cookies in your browser, the website keeps working but you cannot sign in to the application. Cookies set by the iyzico page opened during payment are iyzico's responsibility.

Pages load fonts from Google Fonts. This does not create cookies, but your IP address is sent to Google's servers with the request.