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Privacy Policy

1. Introduction

This Privacy Policy explains how Navlungo Inc. ("Navlungo", "we", "us", or "our") processes personal data of users and customers ("you") when you use our website https://www.parkpalet.com, our services, and our logistics software platform.

Navlungo Inc. is incorporated under the laws of the State of Delaware, United States, with registered office at 24A Trolley Square 1414, Wilmington, DE 19806. For the purpose of the EU General Data Protection Regulation ("GDPR"), we are the data controller when processing personal data.

As we operate within the European Economic Area ("EEA"), particularly in Germany, we comply with the requirements of the GDPR, the German Commercial Code (HGB), the German Fiscal Code (AO), and refer to ADSp 2017 and the Logistics GTC 2019 when applicable in fulfillment and freight operations.

2. Contact Information

Controller: Navlungo Inc., 24A Trolley Square 1414, Wilmington, DE 19806, USA

Email: [email protected]

Representative: İsa Korkmaz

3. Categories of Personal Data We Process

We may collect and process the following categories of personal data:

3. Categories of Personal Data We Process

We may collect and process the following categories of personal data:

  • Contact information (e.g., name, email address, phone number)
  • User data (e.g., IP address, browser data, device identifiers)
  • Order and shipment data (e.g., order contents, recipient addresses)
  • Communication data (e.g., support inquiries, chat logs)
  • Technical and usage data (e.g., pages visited, session duration)
  • Application and employment data (if you apply for a job)

4. Legal Basis for Processing

We process your data on the following legal bases under Article 6 GDPR:

  • Art. 6(1)(a) – Consent (e.g., for marketing cookies)
  • Art. 6(1)(b) – Performance of a contract (e.g., fulfillment and delivery)
  • Art. 6(1)(c) – Legal obligation (e.g., accounting under HGB/AO)
  • Art. 6(1)(f) – Legitimate interests (e.g., fraud prevention, website analytics)

5. Purpose of Processing

We process your data for the following purposes:

  • Providing our fulfillment and logistics services
  • Contract initiation, execution, and support
  • Operating our website and online platform
  • Customer support and onboarding
  • Complying with legal and tax obligations
  • Marketing and analytics (with consent)

6. Data Retention

We retain your data for the following periods:

  • Commercial and tax-related documents are stored for 10 years under § 147 AO and § 257 HGB
  • Communication logs are stored for 6 years (§ 257 HGB)
  • Web usage data is anonymized or deleted after 14 days

7. Data Transfers to Third Parties and Outside the EEA

We may share your data with:

  • Service providers (e.g., AWS, HubSpot, Facebook)
  • Logistics partners (e.g., carriers, warehouse operators)
  • Tax authorities and regulators where legally required

Although Navlungo Inc. is based in the USA, we ensure compliance with GDPR Art. 46 via Standard Contractual Clauses (SCCs) for any international data transfers. No data is transferred outside the EEA without adequate protection.

8. Use of Cookies and Tracking Technologies

We use cookies on our website for the following purposes:

  • Essential cookies – Ensure core site functionality (Art. 6(1)(f) GDPR)
  • Analytics cookies – Measure site usage and improve performance (Art. 6(1)(a) GDPR)
  • Marketing cookies – Deliver personalized advertising (Art. 6(1)(a) GDPR)

Consent for non-essential cookies is obtained via a cookie consent tool.

Third-party tools used

  • Google Analytics (privacy policy)
  • Facebook Pixel (privacy policy)
  • HubSpot (privacy policy)
  • SiteBehaviour Analytics

9. Data Subject Rights

You have the following rights under GDPR:

  • Right to access (Art. 15 GDPR)
  • Right to rectification (Art. 16 GDPR)
  • Right to erasure (Art. 17 GDPR)
  • Right to restriction (Art. 18 GDPR)
  • Right to data portability (Art. 20 GDPR)
  • Right to object (Art. 21 GDPR)
  • Right to withdraw consent (Art. 7(3) GDPR)
  • Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)

10. Data Security

We take appropriate technical and organizational measures to protect your personal data against loss, misuse, unauthorized access, or disclosure. These include:

  • Encrypted data storage
  • Access control and authentication
  • Regular backups and audits

11. Hiring and Recruitment

If you apply for a job at Navlungo, we will process your application data (e.g., CV, contact details, references) for the purpose of evaluating your candidacy. Legal basis: Art. 6(1)(b) and Art. 9(2)(a) GDPR.

We retain candidate data for up to 6 months after completion of the recruitment process unless legal retention periods require otherwise or you consent to longer storage.

12. Updates to This Policy

We reserve the right to update this Privacy Policy from time to time. The latest version will always be available at https://www.parkpalet.com/privacy-policy. Changes are effective upon posting unless otherwise indicated.

13. Contact

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

Navlungo Inc.

24A Trolley Square 1414

Wilmington, DE 19806, USA

Email: [email protected]

Privacy Policy | Parkpalet