Privacy Policy

SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik Data Privacy Policy

Last modified on July 06, 2018.

This data privacy policy describes the collection and further processing of personal data by companies of the SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik and its affiliates (together SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik) as far as they are not covered by other data protection policies or are evident from the circumstances or are provided for by applicable law. The term personal data shall include all information relating to an identified or identifiable person. This data privacy policy describes in section I processing of personal data by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik in general. Section II contains specific provisions for specific applications (e.g. online-shop, newsletter and banner advertisment) and section III contains specific provisions for customer programs. If you provide SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik with personal data of other persons, for example data about the receiver of a gift, please provide their personal data to SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik only if you are allowed to do so pursuant to applicable data protection laws and only if the other person would agree to you providing its personal data to SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik for the purposes the data are collected and the processing of its personal data according to our data privacy policy.

I. General provisions

1. Controller, data protection officer

Every website (including online-shops and mini sites for special offers), every presence on social media, multimedia portals, chatbots and every app of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik (each a website) has a controller within SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik with respect to collecting personal data according to the EU General Data Protection Regulation (GDPR) (or comparable provisions according to applicable data protection laws). Unless provided otherwise on the website (according to the imprint, the terms of use, etc.) or under section II and III below, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik, Turkey, is the controller for the Online-Shop and SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik, Turkey, is the controller for the SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik website www.stonedesignbracelet.com. The respective subsidiary or affiliate is the controller in case SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik communicates through other means of communication (email, letter, telephone, in person, etc.) and the communication does not fall within an activity for which SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik has appointed a specific controller within this data protection policy or otherwise. Should a SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik company or affiliate disclose personal data to another SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik company or affiliate for certain purposes of the receiving company or affiliate, such company or affiliate is the controller. A list of the main companies and affiliates of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik can be found in annex 1, which will be updated from time to time. SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik has not appointed a data protection officer according to article 37 GDPR save for SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik companies and affiliates in Turkey. The data protection officer can be contacted at: For Turkey: contact@stonedesignbracelet.com Furthermore, any inquiry, claim or concern regarding data protection at SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik (all companies and affiliates) can be addressed to the following contact points: The group data privacy team at contact@stonedesignbracelet.com.

2. Processing of personal data

SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik collects and processes personal data of

– users of its websites registered with SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– individuals purchasing and receiving/benefitting from products and services of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– potential or actual parties interested in products and services of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– recipients of newsletters of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– participants in research campaigns and opinion surveys conducted by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– participants in courses, seminars and other training organized by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– users of WIFI provided at SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik stores and other locations;
– individuals ordering or using customer loyalty programs of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik; and
– registered participants of customer loyalty programs of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik (customer program)

(together customers).

The personal data of customers is generally collected directly by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik during the course of using the website, as well as in stores or at events of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik or during direct communication via email, telephone or in any other way. However, personal data can also be collected indirectly, like for example when SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik requests third parties to act as processors, such as for example SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik’s partners (as defined further below, including wholesalers, dealers, retailers, suppli-ers and further business partners such as customer services vendors) and also namely when the customer making the purchase does not correspond with the person benefitting from the purchase or if the purchase is shipped to a different person (e.g. as a gift), based on the recommendation of a third party (e.g. recommendation by family or friends of the customer) or through further acquisition of supplementary information from third party data sources (e.g. social media). In particular, the following categories of personal data is processed by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik:

– Personal data and contact information including but is not limited to first and last name, maiden name, address, residence, telephone number, email address, age, date of birth, gender, marital status, relatives, contact in case of emergency, pictures, etc.;
– Data pertaining to orders and purchases including but is not limited to payment information, credit card details and other payment details, billing and shipping address, products and services ordered and purchased, information connected to queries, complaints and disagreements relating to products and services or respective contracts entered into such as warranty claims, after sales services, repairs, customer care and services, rescissions and disputes, etc.;
– Data in connection with product and services marketing including but is not limited to information such as newsletter opt-ins and opt-outs, documents received, invitations to and partici-pations at events and special activities (as far as they are not part of a customer loyalty pro-gram), personal preferences and interests, customer segmentation information, etc.;
– Data concerning the use of the website including but is not limited to the IP address and other identification (e.g. user name of social media, mac address of smartphones or comput-ers, cookies), date and time of website visits, visited sites and contents, referring websites, etc.
– Data in connection with communication such as preferred means of communication, correspondence and communication with SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik (including records of the communication), etc.;
– Data which was collected in connection with a customer program such as number of mem-bership, access codes (including passwords), preferred language, number of gift certificate, date and duration of the membership, payment information of the customer or a potential third party, information concerning the recipient of a gift, number of visits of the website, purchase history, products acquired, etc. (besides traditional customer loyalty programs, all website accounts, activities and events for which a customer must register with his per-sonal data and thus enter into a contract with SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik shall be deemed a customer pro-gram for the purposes of this policy); together customer data.

In addition, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik collects:

– Data of users of the website, who do not register with SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik (visitor) but may constitute personal data for example with social media (visitor data), the provisions of this policy regarding data collected from a customer in connection with the use of the website shall apply accordingly even though the identification of a visitor usually is not possible for SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– Information pertaining to employees and contacts of their wholesalers, dealers, retailers, suppliers and further business partners (hereinafter natural persons shall be referred to as partners, their data as partner data) such as namely contact details, information regarding their function, information relating to the previous contact with these individuals, data regarding marketing activities (e.g. receipt of newsletters), information regarding business transactions, requests, offers, tenders, conditions and contracts, information related to professional or other interests of the individuals.

Within the framework of their business relationship, customers will be required to provide customer data necessary for the establishment and execution of the contractual relationship and the fulfilment of the associated contractual obligations or required by law. Without this data, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik will generally not be able to conclude or execute the contract with the respective customer. This also applies analogously to the partner data as far as business relations with the wholesalers, dealers, retailers, suppliers and business partners of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik are concerned; these in principle cannot be concluded and processed without information on their employees and other contacts. As any access to the website is logged, connection data (such as the IP address) will always be logged; this is done automatically during the use and cannot be deactivated for individual visitors or customers.

3. Purpose of processing and legal grounds

3.1. Purpose of the processing

In accordance with applicable law, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may process customer data namely for, but not limited to, the following purposes:

– In connection with services offered, conclusions of contracts (namely purchases), executions of contracts (namely purchase contracts and contracts regarding the participation at customer programs and events), maintenance and development of customer relations, communication, customer service and support, promotions, advertisement and marketing (including newsletters and mailing of promotional materials);
– Management of the users of the website and other activities in which customers participate, operation and enhancement of the website (including the provision of functions which require identifiers or other personal data) and further IT systems, identity verifications;
– Protection of customers, employees and other individuals and protection of data, secrets and assets of and entrusted to SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik, safety of systems and premises of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– Compliance with legal and regulatory requirements and internal rules of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik, enforcement and exploitation of legal rights and claims, defense against legal claims, litigation, com-plaints, combating abusive conduct, engaging in legal investigations and proceedings and responding to inquiries of public authorities;
– Sale or acquisitions of business divisions, companies or parts of companies and other corporate transactions and the transfer of customer data associated therewith; and
– For other purposes as far as a legal obligation requires processing and such processing was evident from the circumstances or indicated at the time of the collection.

(together the purpose of customer data processing).

3.2. Legal grounds of processing

SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik uses the customer data for the purpose of customer data processing based on the following legal grounds:

– performance of contracts;
– compliance with legal obligations of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– consent of the customer (only insofar as the processing is based on a specific query and can be withdrawn at any time, namely the receipt of newsletters for which the client has registered for);
– legitimate interests of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik, including but not limited to
– purchase and shipment of products and services, also in connection with individuals who are not direct contractual partners (such as e.g. individuals receiving a gift);
– carrying out advertisement and marketing activities;
– efficient and effective customer support, maintenance of contact and other communi-cation with customers outside of the processing of contracts;
– understanding customer behavior, activities, concerns and needs, market studies;
– efficient and effective improvement of existing products and services and develop-ment of new products and services;
– efficient and effective protection of customers, employees and other individuals as well as protection of data, secrets and assets of or entrusted to SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik, safety of systems and premises of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– maintenance and secure, efficient and effective organization of business operations including a secure, efficient and effective operation and successful further develop-ment of the website and other IT systems;
– reasonable corporate governance and development;
– successful sale and acquisition of business units, companies or parts of companies and other corporate transactions;
– compliance with legal and regulatory requirements and internal rules of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– concerns regarding the prevention of fraud, offences and crimes as well as investigation in connection with such offences and other improper conduct, handling of claims and actions against SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik, cooperation in legal proceedings and with public authorities as well as the prosecution, exercise of and defense against legal actions.

In accordance with applicable data protection laws, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may namely process visitor data for the purpose of maintaining and developing the website (including the provision of functions which require identifiers or other personal data), for statistical analysis regarding the use of the website as well as for combating abusive conduct, for purposes of legal investigations or proceedings and for the response to inquiries of public authorities. The visitor data shall be processed in accordance with the principles set out for customer data above. In accordance with applicable data protection laws, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may process partner data namely for the purpose of entering into and performance of contracts and other business relationships with partners, promotions, advertisement and marketing, communication, invitation to events and partic-ipation in promotions for partners, organization of joint activities, compliance with legal and regula-tory requirements and internal rules of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik, enforcement and exploitation of legal rights and claims, defense against legal claims, litigation, complaints, combating abusive conduct, engaging in legal investigations and proceedings and responding to inquiries of public authorities, for the sale or acquisition of business units, companies or parts of companies and other corporate transaction and related transfers of partner data. The partner data shall be processed in accordance with the principles set out for customer data above. All the purposes of processing shall be applicable for the whole SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik group, i.e. not only for the company which initially collected the personal data. Personal data of customers, visitors and partners is collected for the purpose of all SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik companies subject to applicable data protection laws.

4. Transfer and disclosure of data

In accordance with applicable data protection laws, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may transfer customer data, visitor data and partner data to the following categories of third parties who process personal data in accordance with the purpose of data processing on behalf of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik or for their own purposes:

– service providers (within SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik as well as external), including processors;
– wholesalers, dealers, retailers, suppliers and other business partners;
– customers of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– local, national and foreign authorities;
– media;
– the public including visitors of websites and social media of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– industry organizations, associations, organizations and other committees;
– competitors;
– acquirers or parties interested in acquiring business units, companies or other parts of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;
– other parties in potential or actual legal proceedings;
– other group companies of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik.

(together third parties).

SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may disclose customer data, visitor data and partner data within SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik as well as to third parties and in every country worldwide, including namely all countries in which SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik is represented by Group companies, affiliates or other offices and representatives (see annex 1, as updated from time to time) as well as to countries in which service providers of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik process their data (see annex 1, as updated from time to time). If data is disclosed to countries that do not guarantee adequate protection, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik will ensure adequate protection of data disclosed by customers, visitors or partners by way of putting adequate contractual guarantees in place, namely on the basis of EU standard clauses, or it bases the transfer on the exceptions of consent, conclusion or performance of contract, the determination, exercise or enforcement of legal claims, overriding public interests or it discloses the data in order to protect the integrity of these individuals. The customer, visitor or partner can obtain a copy of the contractual guarantees from or will be advised where to obtain such copies by the contact points named above (see para. 1 above). SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik reserves the right to redact such copies for reasons of data protection or secrecy reasons.

5. Retention of data

In general, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik keeps personal data for no longer than it is necessary for the purposes for which the personal data are processed. However, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may process personal data for longer periods subject to the following rules and obligations: SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik retains personal data as long as SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik (i) is obligated to do so (by way of contract, law or other provisions) or (ii) has an interest in them (namely an interest for reasons of proof in case of claims, documentation of compliance with certain legal or other requirements, an interest in non-personalized analysis). Deviating rules are re-served namely with respect to anonymization or pseudonymization of personal data subject to applicable law. As a rule for contract related customer data and partner data (including business records and communication) SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik retains personal data as long as the contractual relation is ongoing and for ten years after the termination of the contractual relationship unless (i) a shorter or longer statutory storage obligation is applicable on a case-by-case basis, (ii) the retention is required for reasons of proof or another valid reason based on applicable law, or (iii) the deletion of the data is required earlier (namely because the data is no longer required or SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik is required to delete the respective data). As a rule for operational data containing customer data, visitor data or partner data (e.g. protocols, logs), SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik retains personal data for a period of 3 – 12 months.

6. Cookies, Google analytics and social plug-ins

SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik uses cookies on its website. Cookies are a widespread technique that allocates an identification to the browser of the user of a website which the user saves and shows upon request. On the one hand, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik uses session cookies which are automatically erased when the user closes the website and which enable the server to establish a stable connection to the user (so that the content of a shopping basket is not lost, for example) as long as he browses on the website. On the other hand, permanent cookies which are only erased after a period defined per website are used. Permanent cookies allow saving certain settings (e.g. language) for several sessions or allow for an automated log-in. The user consents to the application of permanent cookies by way of using the website and the respective functions (e.g. language settings and automated log-in). The user may block the application of cookies on his browser or delete cookies there which may, however, impair the use of the website. In accordance with applicable law, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may install coding in newsletters and other marketing email which allow it to determine if the recipient has opened an email or downloaded pictures contained in the email. However, the recipient may block this application in his/her email application. In any case he consents to the application of this technology by way of receiving newsletters on other marketing related emails. Should SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik place advertisement of third parties on the website (e.g. banners) or intend to place an own ad on the website of a third party, cookies from companies specializing in the use of such advertisement may be employed. SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik will not disclose personal data to such companies, i.e. they shall only place a permanent cookie with users of the website in order to recognize users and do so in the sole interest of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik. This allows SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik to place aimed advertisements for these individuals on external third party websites (e.g. in connection with products for which these individuals showed an interest in the online-shop). SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik will not disclose personal data to the operators of external websites either. SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may use Google Analytics or similar services on its website. These applications are third party services which allow SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik to measure and analyze the use of its website. The provider of these services may be located in any country worldwide (in the case of Google Analytics which is operated by Google Inc. it is the U.S., www.google.com). The service provider uses permanent cookies for these applications. SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik will not disclose any personal data to the service provider (who will also not save any IP addresses). The service provider may, however, monitor the use of the website by the user and combine this data with data from other websites monitored by the same service provider which the user has visited and the servicer may use these findings for its own benefits (e.g. control of advertisement). The service provider knows the identity of the user who has registered with the service provider. In this case the processing of personal data will be the service provider’s responsibility and data shall be processed according to the data protection policies of the service provider. The service provider will provide data on the use of the website to SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik. In addition, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may use plug-ins from social media networks such as Facebook, Twitter, Youtube, Google+, Pinterest or Instagram on its website. In the default setting of the website plug-ins are deactivated; the user can thus choose when to activate them. Should the user do so, the social media providers are able to establish a direct connection to the user during his visit on the website, which allows the provider to be aware of the user’s visit and may analyze the respective information. The subsequent processing of the personal data will be conducted in the responsibility of the provider and according to his data protection policies. The provider of the respective social media offering will not disclose any information to SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik.

7. Rights of the customer, visitors and partners

Any affected individual, including any customer, visitor and partner, may request information from SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik as to whether data concerning them is being processed. In addition, they have the right to request the correction, destruction or restriction of personal data regarding them as well as to object to the processing of personal data. Should the processing of personal data be based on con-sent, the affected individual may withdraw consent at any time. In countries of the EU and EEA the affected individual may, in certain cases, have the right to obtain data generated during the use of online services in a structured, common and machine-readable format which allows for further use and transfer. Request in this respect shall be submitted to the contact point (see para. 1 above). SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik reserves the right to restrict the rights of the affected individual in accordance with applicable law and e.g. not to disclose comprehensive information or not to delete data. Should SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik make an automated decision with respect to a certain individual which may have a legal effect for the affected individual or seriously affect her in a similar way, the affected individual shall have, in accordance with applicable law, the right to communicate with a controller of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik and to request a reconsideration of the decision or to request the prior evaluation by the controller. In this case the affected individual might no longer be able to use certain automated services. The individual will be informed thereof subsequently or separately in advance. Any affected individual may also raise a complaint with the competent data protection authority, which in the case of a SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik controller in Turkey is the Federal Data Protection and Information Commissioner in Turkey.

8. Changes to the data privacy policy

SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik is entitled to amend this data privacy policy at any time and without prior notice or announcement. The latest version according to the website shall be applicable. Should the data privacy policy form part of an agreement with customers and partners, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may inform them of an update or amendments by email or in another appropriate manner. The amendments shall be deemed to have been accepted unless an objection is raised within 30 days of notification. In case of objection SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik shall be free to terminate the agreement exceptionally and with immediate effect.

II. Specific provisions

The following provisions shall supplement the provisions of the general part for certain activities of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik. In the event there is any inconsistency, the following provisions shall prevail the provisions of the general part.

1. Online shops

The creditworthiness of customers may be evaluated automatically in online shops in order to offer the purchase on account based on this decision as far as this payment option shall be offered at all. In this case the credit rating is evaluated on the basis of information from an external credit rating agency, which will provide SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik with a credit score of the respective customer. The agency will calculate the score based on a secret formula based on data on the payment history of the customer, its debt and insolvency history and possible limitations of its legal capacity. Should the score be below a certain threshold no payment by invoice will be offered. In this event the customer may con-tact the contact person shown on the imprint of the respective website of the online-shop if he is not ready to accept the decision. Online shops of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may automatically decide whether to enter into purchase agreements. However, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik does not deem this an automated individual decision (according to article 22 GDPR). In the event the customer does not wish such an automated entering into an agreement, it has the option to purchase products and services from SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik at physical stores run by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik and its retailers.

2. Partners, including wholesalers, retailers, dealers, customer service vendors etc.

As previously indicated, customer data, partner data and visitor data is generally collected directly by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik but also indirectly, like for example when SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik requests third parties to act as processors, such as SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik’s partners. In these cases, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik’s partners process personal data on behalf and under instruction of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik and are bound by specific processor agreements covering the terms and conditions of their duties in a manner to ensure the protection of the rights of our customers, partners and visitors and the processing and security of their personal data in accordance with applicable data protection laws.

3. Newsletter and banner advertisement

SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may send newsletters or other commercial communications in connection with its products and services to customers and partners. In accordance with applicable law, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik reserves the right to do so without prior consent of existing customers and business partners. However, the respective customers and business partners may object to a further mailing of newsletters or other commercial communications at any time through their account on the respective website or through the link indicated in every mailing. However, the termination of one newsletter may not entail the termination of other newsletters, as well. It is possible that personalized advertisement is placed during the visit on the website. Every banner advertisement displayed to the customer contains products offered on the website which have previously been looked at by the customer. The advertisement is generated by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik by the means of cookies (see section I para. 6 above).

4. Sweepstakes and other promotional activities

The following provisions shall be applicable for the processing of data by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik in connection with customer swepstakes and other promotional activities. The data in connection with the sweepstake and other promotional activties is basically processed by head Office in Turkey. Other companies and affiliates of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may however use the collected personal data for their purposes according to section I para. 3 above.

As far as the sweepstake and other promotional activities are concerned, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik namely processes the personal data of participants according to section I para. 2 above. for the purposes listed under that respective provision, and in particular also for the following purposes in accordance with applicable laws:

– carrying out the competition;
– contacting winners;
– publication of the contact details of the winners
– promote winners on social media,
– promotional and marketing activities.

Further information regarding the sweepstake and other promotional activities can be found in the specific terms and conditions applicable to each sweepstake and promotional activity, as published and organized from time to time.

III. Specific privacy policy for customer programs

2. SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik loyalty program

The following provisions shall be applicable for the processing of data by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik in connection with the SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program.

a. Responsible for the personal data (Controller)

The personal data in connection with the membership of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program is processed by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik head Office in Turkey. Other companies and affiliates of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may however use the collected personal data for their purposes according to section I para. 3 above.

b. Processing of personal data and source

SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik collects and saves the personal obligatory data provided on the SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program application form (including but not limited to: title, name and address, and email address) plus any personal data provided voluntarily by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program members on the application form: date of birth as well as interest in Jewellery and Accessories, Home and Style, Wedding, Figures and Collectables and/or Watches (“Form Data”). In SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik also saves data on members’ purchase history in the form of items purchased (product designation, price, discount), place and time of purchase and membership number. The purchase history is recorded if the SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program membership number is communicated at the checkout for purchases in stores participating in SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program. In the online store members’ purchase history is recorded if the membership number is quoted when making a purchase or the member makes a purchase when logged into an online account associated with a SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program membership. SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik also collects and saves all vouchers sent to the SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program member. Where SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik believes that two different SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program memberships belong to the same individual, or where a valid request is received, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may merge them.

c. Purpose of processing

As far as SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program is concerned, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik namely collects and processes the personal data of members of the customer loyalty program according to section I para. 2 above and as specified below for the purposes listed under that respective provision, and in particular also for the following purposes:

– administration of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program memberships;
– operation of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program, namely personalized offers and communications regarding products and services of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik, providing of advantages and awarding special conditions (e.g. vouchers), invitations to special events and promotions reserved for members, participating in surveys, requiring feedback and act in social media.

The personal data collected is used by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik to administer and manage the membership (including also for accounting purposes), to provide the member with the benefits and other services that come with the membership (the legal basis for this is the membership). In participating stores, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program allows members to take advantage of an extended customer advice in which, upon presentation of the membership number, the store employee can call up the member’s purchase history data and provide the member with additional sales advice based on his or her past purchases. On presentation of the SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program membership number or of an official ID document together with the member’s name and date of birth (or another unique authentication attribute), the relevant store employee has access to the relevant member’s saved purchase history data. SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may also use the personal data to invite selected members to special events and promotions, such as the presentation of new products or discount promotions. In addition, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik also uses the personal data to send members birthday congratulations. SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik also uses the data collected in the purchase history to grant members membership benefits in the form of discount or loyalty gift vouchers. Based on the data saved in the purchase history, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik evaluates what type of voucher the member is granted. If a member has given SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik his or her consent, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may send the member further information about SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik, product information, services and exclusive offers by email or in any other way chosen by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik. Based on the form data and the purchase history reported by participating stores as well as other information voluntarily disclosed to SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik by the SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program member, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may personalize the information sent to the member so that the member particularly receives, where possible, information which SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik seems interesting for the member. For this purpose, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik analyses the form data collected at the start of membership and, in particular, takes account of the saved information relating to age, sex, interests and preferences, as well as the vouchers received, and other information that can be gleaned from the purchase history or has been given to SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik by the member voluntarily at any later time.

d. Disclosure of personal data

In the course of processing personal data in connection with SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik may namely disclose personal data to the following categories of recipients:

– Partners, including business, marketing and promotion partners and all participating retail shops or other authorized specialists dealers, irrespective of whether the company is run by SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik or another sales or cooperation partner; whereas these stores may be located within any country worldwide and they may use data received from SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik only for the purpose of operating SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program, including personalized offers to and communication with members on behalf of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik;

– to a SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik company to whom the processing of data (operation of the database) regarding SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program has been outsourced in technical respect (processors). Each recipient may be located in a country without an adequate level of data protection. If that is the case, SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik will ensure an adequate level of protection according to section I para. 4 above.

e. Rights of data subjects

SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program members are entitled at any time to ask SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik for information relating to their saved personal data, and other information as provided for by applicable data protection law as according to section I para. 7 above.

f. Data retention

Personal data will be held and used for the duration of the membership; thereafter, it will be retained as long as necessary for the aforementioned purposes, but not for more than five years, unless required for legal reasons. The purchase history is recorded for five years.
Further information regarding SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik customer loyalty program can be found in the general terms and conditions of the customer loyalty program.

Annex 1 – List of SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik legal entities

SDB (Stone Design Bracelet) – Taki Tasarim Danismanlik, Istanbul, Turkey