PRIVACY POLICY

Your Personal Data is valuable and important to us. The purpose of this document (“Privacy Statement”) is to inform you of how Misha Shipping manages Personal Data which is subject to the Turkish Personal Data Protection Act (No. 6698 dated 24/3/2016) (“the Act”). Please read this Privacy Statement so that you know and understand the purposes for which we collect, use and disclose your Personal Data. By interacting with us, submitting information to us, enrolling or signing up for services offered by us, you agree and consent to the Misha Shipping (including and their respective related corporations) (collectively, the “Companies”), as well as their respective representatives and/or agents (“Representatives”) (the Companies and Representatives collectively referred to herein as “ Misha Shipping “, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies’ authorized service providers and relevant third parties in the manner set forth in this Privacy Statement. This Privacy Policy supplements but does not supersede nor replace any other consent you may have previously provided to Misha Shipping in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have at law to collect, use or disclose your Personal Data. Misha Shipping may from time to time update this Privacy Statement to ensure that this Privacy Statement is consistent with our future developments, industry trends, and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Statement as updated from time to time on our website www.mishaship.com/privacyPolicy Please check back regularly for updated information on the handling of your Personal Data.

1. Personal Data

In this Privacy Statement, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organization has or is likely to have access, including data in our records as may be updated from time to time.

Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, passport or other identification numbers, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, (including in the form of biometric data), or via other forms of interaction with you.

2. Collection of Personal Data

2.1 Generally, we collect Personal Data in the following ways:

i. when you use our electronic services, or interact with us via websites or use services on our websites;

ii. when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions, and other initiatives;

iii. when we receive references from business partners and third parties, for example, where you have been referred by them;

iv. when you submit your Personal Data to us for business-related reasons.

v. When you browse our website, you generally do so anonymously but please see the section below on cookies. Our website does not automatically collect Personal Data, including your email address unless you provide such information or log in with your account credentials.

vi. when you submit any form, including but not limited to application, declaration, proposal or referral forms;

vii. when you use some of our services provided through online and other technology platforms, eg. websites and apps including when you establish any online accounts with us;

viii. when you interact with our staff, including customer service officers and other representatives, for e.g. via telephone calls (which may be recorded), letters, face-to-face meetings, digital platforms (including social media), and email;

ix. when you are contacted by, and respond to, our marketing representatives and agents and other service providers;

x. when we seek or receive information about you in connection with your application, registration, claims for example, from other parties, marine/seafarer associations, hospitals, clinics, your ex-employer, and the relevant authorities; and/or

xi. when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;

2.2 You as a user of our platform services should ensure that all Personal Data submitted to us is complete, accurate, true, and correct. If there is a change to your contact information such as your home address, email address or telephone number, company contact, please promptly update us. This ensures that you will continue to receive communications from us without disruption or delay. Failure on your part to do so may result in our inability to provide you with the services you have requested.

3. Purposes for the Collection, Use, and Disclosure of Your Personal Data

3.1 Generally, Misha Shipping collects, uses, and discloses your Personal Data for the following purposes:

i. responding to, processing, and handling your queries, complaints, feedback, suggestions, and requests;

ii. verifying your identity;

iii. managing the administrative and business operations of the Companies and complying with internal policies and procedures;

iv. facilitating business transactions

v. matching any Personal Data held which relates to you for any of the purposes listed herein;

vi. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling, or other purposes for us to design our products, understand customer behavior, preferences, and market trends, and to review, develop and improve the quality of our services;

vii. preventing, detecting, and investigating crime, including fraud and money-laundering or terrorist financing, and analyzing and managing commercial risks;

viii. project management;

ix. providing media announcements and responses;

x. organizing promotional events; marketing purposes (Online/Offline)

xi. in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;

xii. complying with any applicable rules, laws, and regulations, codes of practice or guidelines or to assist in law enforcement

xiii. any other purposes relating to the aforesaid.

3.2 In addition, Misha Shipping platform collects, uses, and discloses your Personal Data for the following purposes depending on the nature of our relationship:

a. If you are a prospective buyer, supplier, or distributor

i. where account or relationship managers or agents have been assigned to service your account or portfolio, we may also use your telephone number(s) to contact you from time to time in order to take your instructions, and/or provide you with information, updates, or recommendations and/or in accordance with the terms and conditions of our agreement with you;

ii. arranging contracts of goods or agreements

iii. assessing and processing any applications or requests made by you for services offered by Misha Shipping platform;

iv. customer outreach and relationship management;

v. archival management (including but not limited to warehouse storage and retrievals); communicating with you (including by way of telephone calls) in relation to your registration and informing you of updates to the registration, terms, and conditions and providing administrative information, including for the purposes of servicing you in relation to the products and services offered to you;

vi. administering, maintaining, managing, and operating the services offered to you

vii. sending updates and administrative notices to you in relation to the services used by you

viii. any other purposes relating to the aforesaid.

b. If you submit an application or registration to us as a candidate for employment (crewing section)

i. processing your application including pre-recruitment checks, such as in qualifications;

ii. providing or obtaining employee references and for background screening/vetting;

iii. facilitating and arranging interviews;

iv. assessing your suitability for the position applied for;

v. communicating with you as required by Misha Shipping to comply with its policies and processes, including for business continuity purposes;

vi. processing staff referrals;

vii. any other purposes relating to the aforesaid.

You should ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Failure on your part to do so may result in delays in the processing of your application, or our inability to process your application.

c. If you are a Member of the Misha Shipping Programme (“Misha Shipping”)

i. providing communication products, in particular, to convey the communications you make by means of our services;

ii. offering and informing you of the benefits under the Programme;

iii. informing you about service updates, delays, and/or faults;

iv. requesting feedback or participation in online surveys;

v. conducting market research for statistical, profiling, or other purposes;

vi. organizing and carrying out marketing or promotional operations and similar events; and

vii. any other purposes relating to the aforesaid.

d. If you are an employee, officer, or owner of an external service provider or vendor outsourced or prospected by Misha Shipping:

i. managing supply of services;

ii. processing and payment of vendor invoices; and/or

iii. any other purpose relating to any of the above.

3.3 If you are submitting an application for or purchasing a Misha Shipping product/services through any forms of payment gateways e.g. Paypal, Credit Cards, or any other payment vendors which we may change solely on Misha Shipping discretion.

3.4 In addition, where permitted under the Act, Misha Shipping may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):

i. providing or marketing services, products, and benefits to you, including promotions, loyalty and reward programs;

ii. matching Personal Data with other data collected from time to time for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by any of the Companies or other third parties;

iii. sending you details of products, services, special offers, and rewards, either to our customers generally, or which the Companies have identified may be of interest to you; and

iv. conducting market research, understanding and analyzing customer behavior, location, preferences, and demographics for the Companies to offer you products and services as well as special offers and marketing programs that may be relevant to your preferences or profile.

3.5 If you have provided your mobile telephone number(s) and have indicated that you consent to receive marketing or promotional information via your telephone number(s), then from time to time, Misha Shipping may contact you using such telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services (including discounts and special offers).

3.6 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

4. Disclosure of Personal Data

4.1 Misha Shipping will take reasonable steps to protect your Personal Data against unauthorized disclosure of personal data. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located in Turkey or overseas:

i. Misha Shipping related corporations;

ii. companies providing services relating to the operations within Misha Shipping;

iii. agents, contractors or third-party service providers who provide operational services to Misha Shipping, such as courier services, telecommunications, information technology, payment, processing, training, market research, customer support investigation services, or other services to Misha Shipping;

iv. vendors or other third-party service providers in connection with products and services offered by Misha Shipping credit reporting agencies, or in the event of default or disputes, any debt collection agencies or dispute resolution centers

v. where we require payment from you, your banks, credit card companies, and their respective service providers;

vi. third party referrers;

vii. our co-brand and other business partners;

viii. external business in relation to corporate promotional events;

ix. our professional advisers such as our auditors and lawyers;

x. relevant government regulators or authority or law enforcement agency to comply with any laws, rules and regulations or schemes imposed by any governmental authority such as the Monetary Authority of Turkey, the Ministry of Manpower, and

xi. any other party to whom you authorize us to disclose your Personal Data.

5. Use of Cookies

5.1 When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may deploy cookies in order for our server to recognize a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s clickstream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

5.2 Cookies are small text files placed in the ‘Cookies’ folder on your computing or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.

5.3 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

6. Data Security

6.1 Misha Shipping will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example, no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware, or adware). You should be aware of the risks associated with using websites.

6.2 While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

6.3 If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorized person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorized transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorized and/or fraudulent use of your username and password.

7. Anti-Spam

7.1 If you receive spam messages and want to report it to us, please forward the message you have received to misha@mishaship.com

8. Third-Party Sites

8.1 Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third-party websites. Some of these third-party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

9. Contacting Us – Feedback, Withdrawal of Consent, Access, and Correction of your Personal Data

9.1 If you: i. have any questions or feedback relating to your Personal Data or our Privacy Statement;

ii. would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Statement; or

iii. would like to obtain access and make corrections to your Personal Data records

Please contact Misha Shipping as follows:

Email: misha@mishaship.com

Call: +90-216-3910139

Write in:

Misha Shipping Agency and Trade Ltd.

Selimiye, Selvikoku Sok. Pembekose Apt. No: 1/8 34668 Uskudar - Istanbul / TURKEY

9.2 Please note that if your Personal Data has been provided to us by a third, you should contact that individual to make such queries, complaints, and access and correction requests to Misha Shipping on your behalf.

9.3 You may refuse to give or may withdraw your consent for us to collect, use or disclose your Personal Data and/or your insured persons’ Personal Data by giving us reasonable notice so long as there are no legal or contractual restrictions preventing you from doing so. For example, you may withdraw your consent for your Personal Data being used for marketing purposes if this withdrawal will not affect our ability to provide you with the products and services that you asked for or have with us.

9.4 However, if you withdraw your consent for us to use your Personal Data for any purposes which we regard as necessary to provide you products and services supplied by or through us, such as for example, matters relating to the servicing and administration of your registration with Misha Shipping, this may affect our ability to provide you with such products and services, including preventing us from keeping maintaining in force your personal data or properly assessing any issues/matters pertaining to the operation within Misha Shipping. Withdrawing such consent may also result in the termination of all your policies and contractual relationships with us. There may be other consequences of your withdrawal which Misha Shipping may advise you of. In the event of any withdrawal of your consent in relation to your Personal Data, Misha Shipping's legal rights and remedies are expressly reserved.

10. Governing Law

10.1 This Privacy Statement and your use of this website shall be governed in all respects by the laws of Turkey.  

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