Privacy and Personal Data Protection Policy and Communication Statement

Dear Members and Customers;

We hereby inform you about our privacy policy, communication procedures, terms of use on the website and our practices about processing of your personal data and your rights under the Law on the Protection of Personal Data.

The following principles shall apply to the collection, storage, transfer or processing of your personal data by Sev Triko San. ve Tic. Ltd. Şti.. (“Nitt Studio” or “we/us"):

How do we collect your personal data?

-       Personal Data Provided to us Directly by you

• Your basic personal information such as your name, Personal ID Number, address, e-mail address and date of birth;
• Your shopping history;
• Your payment details;
• Your marketing and communication preferences.

Purposes of Processing Your Personal Data

Your personal data is used specifically to:

• Communicate with our customers regarding the conditions, current status and updates of contracts concluded under the Consumer Protection Law and the Regulations on Distance Sales Contracts, and provide them with necessary information;
• Perform the obligations undertaken in accordance with the provisions of the Consumer Protection Law and the Regulations on Distance Sales Contracts;
• Direct our customers to the product that may be of interest to them, by taking into account their shopping experiences and giving them information about campaigns;
• Increase customer satisfaction, get to know our customers who are doing shopping on websites and/or mobile applications and use this information for analyzing our customer profile, for marketing and advertising activities and conduct surveys in electronic and/or physical environment through contracted suppliers;
• Give suggestions to our customers through our contracted suppliers and business partners and inform our customers about our services;
• Evaluate customer complaints and suggestions related to our services; and
• Meet our obligations and exercise our rights under the current laws and regulations.

You will be more clearly informed about the purposes of collecting and processing of your personal data if the law requires us to do so.

To Whom and How do we Transfer your Personal Data?

We may transfer any part of the personal data we collect to our business partners or collect your personal data therefrom for the campaigns we organize with your consent, in accordance with the law. Nitt Studio may disclose your personal data to third parties for determining their products and services that may be of interest to you in accordance with your preferences for such third parties' direct marketing purposes.

Your personal data may be used for research and statistical purposes such as analyzing your website and mobile applications traffic data, preferences and interests.

We may use your personal data in order to prevent crime and fraud and to control and/or to ensure Nitt Studio' compliance with the law, without any obligation of sending a notice to you or obtaining your express consent.

Your personal data may be disclosed to third parties in the following cases:

• Request from competent authorities;
• For the safety of our employees, the public and Nitt Studio;
• For fulfilling legal proceedings, judicial orders or legal and/or regulatory procedures;
• As part of a merger, sale of assets or similar transactions.

We may disclose your personal data to third party service providers that provides us with services such as support for the management and storage of information systems, data analysis, etc.

However, unless you opt out to receive direct marketing messages, we may transfer your personal data to third parties which help us for market research and marketing campaigns.

Commercial Electronic Messages

We may send you updates and offers for the products and campaigns of Nitt Studio and other brands thereof through direct marketing methods (e.g. phone, e-mail, SMS, social networks and mail) if you have opted to receive them.

Accordingly, we may use your other personal data which have been provided to us for determining our products, services and their prices, making them more suitable to your requests, gathering them and offering discount that may be of interest to you.

Whenever you are contacted through e-mail, message or other direct marketing means, you will have a choice of "opt-out". Further, you can contact us at any time to change your choice on marketing.

Pursuant to the Law no. 6563 on the Regulation of Electronic Commerce, records of the withdrawal of the approval will be retained for 1 year from the date of withdrawal, whereas the contents of commercial messages and any other related record will be retained 3 years for submitting to the relevant ministry, if required. Upon the expiration of these periods, your personal data will be deleted, destroyed or anonymized by Nitt Studio or upon your request

Use of Third Party Cookies in Advertising and Retargeting

When you visit our website, your personal data is processed through "cookies" and "beacons" or similar technologies to improve your online experience by remembering you.

Nitt Studio brand (Nitt Studio) uses session cookies and permanent cookies in their mobile applications. The session ID cookie disappears when you close your browser. A persistent cookie remains in your hard disk for a long time. You can remove persistent cookies and reject both session cookies and persistent cookies by following the instructions in your browser's "help" file or by visiting "www.allaboutcookies.org" or "www.youronlinechoices.eu". If you reject persistent cookies or session cookies, you may continue to use the website and mobile application, but you may not have access to the full functionality of the website and the mobile application, or your access may be limited.

Where any product/service is purchased as a result of the communication with the member, and information, promotions and advertisements provided to her/him, this purchase will also be subject to the Distance Sales Contract to be made as per the law. The terms and conditions of the Distance Sales Contract shall apply to  both parties. When you purchase something from our site, the provisions of the preliminary order information-distance sales contract that will display at each transaction will be valid.

When you visit our Web site, we may record your personal data such as hardware and software used, your whereabouts, when and how you access our web site. These personal data are used to present products that may be of interest to you, improve customer experience, set prices and/or inform you of campaigns.

If you have opted to receive direct marketing messages from us by email, we may also use technologies such as pixel tags or links to determine your level of interest in direct marketing materials.

When you visit our Web site, we automatically register the IP address of your computer.

Membership

When you register for a membership of our website or do shopping without becoming a member, you can suspend or cancel your membership or register for a membership again.

Protection of Your Personal Data

We do not transfer your personal data to third parties without your prior consent in accordance with the foregoing principles, laws, sanctions, our privacy policy and responsibilities. However, we may disclose your personal data to the courts and other public authorities in the manner and to the extent that our legal obligations require.

Nitt Studio receives your personal data using Secure Sockets Layer (SSL) generally recognized by websites and discloses such data in the same security layer with your prior consent. All legal measures are taken when your personal data is transferred to third parties with your prior consent. Nitt Studio shall not be liable for the data protection policies of the third parties which received the personal data and any violation that occurs when the personal data is in the possession of a third party.

Access to, Editing and Deleting Your Personal Data

It is important to keep your personal data accurate and up-to-date. So, please let us know any change in your personal data. You can edit your personal data in your profile using the "My Account" section in the website.

However, according to the Law no. 6698 on Protection of Personal Data and associated regulations, as the personal data holders, you are entitled to: 

• learn whether your personal data is processed,
• request information if your personal data has been processed,
• learn the purpose of processing and whether the data is used in accordance with that purpose, and the recipients to whom your personal data has been disclosed at home or abroad,
• request the correction of any inaccurately or incompletely processed personal data,
• request the erasure or destruction of your personal data if the reasons justifying the processing of your personal data have disappeared,
• object to any result against you due to the analysis of the processed personal data exclusively by automatic systems, and
• claim compensation for damage you suffer as a result of any unlawful processing of your personal data.   

Amendment to the Privacy Policy

The Privacy Policy may be amended from time to time. The Privacy Policy will be announced on our website when it is amended.

Contact Us

If you have any question or concern  regarding our Privacy Policy or other data protection practices, or if you have an access request, you can contact us using the application form at the following addresses:

E-mail: hello@nittstudio

Contact address: ..................

Phone number:

 

This Privacy Policy describes how nittstudio.com (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit or make a purchase from the Site.

Collecting Personal Information

When you visit the Site, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases. We may also collect additional information if you contact us for customer support. In this Privacy Policy, we refer to any information that can uniquely identify an individual (including the information below) as “Personal Information”. See the list below for more information about what Personal Information we collect and why.

Device information

• Examples of Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
• Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
• Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels [ADD OR SUBTRACT ANY OTHER TRACKING TECHNOLOGIES USED].
• Disclosure for a business purpose: shared with our processor Shopify [ADD ANY OTHER VENDORS WITH WHOM YOU SHARE THIS INFORMATION].

Order information

• Examples of Personal Information collected: name, billing address, shipping address, payment information (including credit card numbers [INSERT ANY OTHER PAYMENT TYPES ACCEPTED]), email address, and phone number.
• Purpose of collection: to provide products or services to you to fulfill our contract, to process your payment information, arrange for shipping, and provide you with invoices and/or order confirmations, communicate with you, screen our orders for potential risk or fraud, and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
• Source of collection: collected from you.
• Disclosure for a business purpose: shared with our processor Shopify [ADD ANY OTHER VENDORS WITH WHOM YOU SHARE THIS INFORMATION. FOR EXAMPLE, SALES CHANNELS, PAYMENT GATEWAYS, SHIPPING AND FULFILLMENT APPS].

Customer support information

• Examples of Personal Information collected: [MODIFICATIONS TO THE INFORMATION LISTED ABOVE OR ADDITIONAL INFORMATION AS NEEDED]
• Purpose of collection: to provide customer support.
• Source of collection: collected from you.
• Disclosure for a business purpose: [ADD ANY VENDORS USED TO PROVIDE CUSTOMER SUPPORT]

[INSERT ANY OTHER INFORMATION YOU COLLECT: OFFLINE DATA, PURCHASED MARKETING DATA/LISTS]

[INSERT FOLLOWING SECTION IF AGE RESTRICTION IS REQUIRED]

Minors

The Site is not intended for individuals under the age of [INSERT AGE]. We do not intentionally collect Personal Information from children. If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.

Sharing Personal Information

We share your Personal Information with service providers to help us provide our services and fulfill our contracts with you, as described above. For example:

• We use Shopify to power our online store. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy.
• We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
• [INSERT INFORMATION ABOUT OTHER SERVICE PROVIDERS]

[INCLUDE FOLLOWING SECTION IF USING REMARKETING OR TARGETED ADVERTISING]

Behavioural Advertising

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:

• [INSERT IF APPLICABLE] We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en.You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
• [INSERT IF YOU USE A THIRD PARTY MARKETING APP THAT COLLECTS INFORMATION ABOUT BUYER ACTIVITY ON YOUR SITE] We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
• [INSERT OTHER ADVERTISING SERVICES USED]

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

[INCLUDE OPT-OUT LINKS FROM WHICHEVER SERVICES BEING USED. COMMON LINKS INCLUDE:

• FACEBOOK - https://www.facebook.com/settings/?tab=ads
• GOOGLE - https://www.google.com/settings/ads/anonymous
• BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads]

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

Using Personal Information

We use your personal Information to provide our services to you, which includes: offering products for sale, processing payments, shipping and fulfillment of your order, and keeping you up to date on new products, services, and offers.

[INCLUDE THE FOLLOWING SECTION IF YOUR STORE IS LOCATED IN OR IF YOU HAVE CUSTOMERS IN EUROPE]

Lawful basis

Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:

[INCLUDE ALL THAT APPLY TO YOUR BUSINESS]

• Your consent;
• The performance of the contract between you and the Site;
• Compliance with our legal obligations;
• To protect your vital interests;
• To perform a task carried out in the public interest;
• For our legitimate interests, which do not override your fundamental rights and freedoms.

Retention

When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

We [DO/DO NOT] engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.

Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

• Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
• Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.

[INCLUDE THE FOLLOWING SECTION ONLY IF YOU SELL PERSONAL INFORMATION, AS DEFINED BY THE CALIFORNIA CONSUMER PRIVACY ACT]

Selling Personal Information

Our Site sells Personal Information, as defined by the California Consumer Privacy Act of 2018 (“CCPA”).

[INSERT:

• CATEGORIES OF INFORMATION SOLD;
• INSTRUCTIONS ON HOW TO OPT-OUT OF SALE;
• WHETHER YOUR BUSINESS SELLS INFORMATION OF MINORS (UNDER 16) AND WHETHER YOU OBTAIN AFFIRMATIVE AUTHORIZATION;
• IF YOU PROVIDE A FINANCIAL INCENTIVE TO NOT SELL INFORMATION, PROVIDE INFORMATION ABOUT WHAT THAT INCENTIVE IS.]

Your rights

[INCLUDE FOLLOWING SECTION IF YOUR STORE IS LOCATED IN OR IF YOU HAVE CUSTOMERS IN EUROPE]

GDPR

If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below [OR INSERT ALTERNATIVE INSTRUCTIONS FOR SENDING ACCESS, ERASURE, CORRECTION, AND PORTABILITY REQUESTS].

Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States. For more information on how data transfers comply with the GDPR, see Shopify’s GDPR Whitepaper: https://help.shopify.com/en/manual/your-account/privacy/GDPR.

[INCLUDE FOLLOWING SECTION IF YOUR BUSINESS IS SUBJECT TO THE CALIFORNIA CONSUMER PRIVACY ACT]

CCPA

If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below [OR INSERT ALTERNATIVE INSTRUCTIONS FOR SENDING ACCESS, ERASURE, CORRECTION, AND PORTABILITY REQUESTS].

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address below.

Cookies

A cookie is a small amount of information that’s downloaded to your computer or device when you visit our Site. We use a number of different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information each time you return to the site or browse from one page to another. Cookies also provide information on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor.

We use the following cookies to optimize your experience on our Site and to provide our services.

Cookies Necessary for the Functioning of the Store

Name	Function
_ab	Used in connection with access to admin.
_secure_session_id	Used in connection with navigation through a storefront.
cart	Used in connection with shopping cart.
cart_sig	Used in connection with checkout.
cart_ts	Used in connection with checkout.
checkout_token	Used in connection with checkout.
secret	Used in connection with checkout.
secure_customer_sig	Used in connection with customer login.
storefront_digest	Used in connection with customer login.
_shopify_u	Used to facilitate updating customer account information.

Reporting and Analytics

Name	Function
_tracking_consent	Tracking preferences.
_landing_page	Track landing pages
_orig_referrer	Track landing pages
_s	Shopify analytics.
_shopify_s	Shopify analytics.
_shopify_sa_p	Shopify analytics relating to marketing & referrals.
_shopify_sa_t	Shopify analytics relating to marketing & referrals.
_shopify_y	Shopify analytics.
_y	Shopify analytics.

[INSERT OTHER COOKIES OR TRACKING TECHNOLOGIES THAT YOU USE]

The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device.

You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.

Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through such sites as www.allaboutcookies.org.

Additionally, please note that blocking cookies may not completely prevent how we share information with third parties such as our advertising partners. To exercise your rights or opt-out of certain uses of your information by these parties, please follow the instructions in the “Behavioural Advertising” section above.

Do Not Track

Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

Changes

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Contact

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email address] or by mail using the details provided below:

Sevtriko san. ve tic. ltd sti, Üniversite mahallesi civan sokak No-6 Avcılar, 34320 istanbul , Turkey

Last updated: [DATE]

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: [ADD CONTACT INFORMATION OR WEBSITE FOR THE DATA PROTECTION AUTHORITY IN YOUR JURISDICTION. FOR EXAMPLE: https://ico.org.uk/make-a-complaint/]