PRIVACY POLICY
Posted on 03-03-2025
Last Updated 03-03-2025
AYAYDIN MIROGLIO GENERAL TRADING L.L.(referred to as "Company”, “We”, “Us” or “Our” in this Policy), collects and Processes users' (referred to as "You", "Your", and "User(s)") personal information and data (referred to as "Data") collected upon Your installation and usage of our mobile application IPEKYOL (referred to as "Application" or “App”) and Website
ae.ipekyol.com (referred to as the “Website”), both of which are owned and operated by Us. In accordance with Our legal duty to collect, store, Process, use, and protect the privacy of the collected Data, We hereby commit to the protection thereof in accordance with the terms of this Privacy Policy (referred to as “Policy”). Please read the Policy carefully before proceeding with the installation of the App and accessing our Website. If you do not agree with the terms of this Policy, please do not proceed with the installation of the App and exit the Website immediately.
We inform our users on how we collect, use, share, and protect their personal data. Every time you interact with IPEKYOL through either our physical stores or e-commerce websites or apps, and engage our services, you agree to the use of your data that is collected or submitted as stated in this Policy.
Under the relevant data protection rules and regulations governing Us, We are required to provide You with certain information about who We are, how We Process Your Data and for what purposes, and Your rights in relation to the collected Data. This information is provided in this Policy and it is important that you read and understand that information before proceeding with the installation of the App and usage of the Website.
You are hereby informed that the installation of the App and access to the Website shall result in Us collecting and Processing Your Data and therefore, please indicate your consent to the installation of the App and usage of the Website Our Processing of Your Data.
CONSENT TO INSTALLATION OF THE APP and TO ACCESS TO THE WEBSITE
YES, I have read and understood the terms of this Policy and provide my informed consent to the installation of the App and access to the Website for the purpose of my personal use and the Processing and usage of the Data by the Company in accordance with the terms set out in this Policy.
Changes to the Policy and Your duty to inform Us of changes
We keep Our Policy under regular review.
This version was last updated on [03.03.2025]. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to You when You next start the App and visit the Website. The new policy may be displayed on-screen, and You may be required to read and accept the changes to continue Your use of the App and Website.
It is important that the Data that You have provided about You is accurate and up to date. Therefore, please keep Us informed if Your Data changes during Our relationship with You.
INTRODUCTION
This Policy applies to Your use of:
• IPEKYOLmobile application software hosted in App Store, once You have downloaded or streamed a copy of the App onto Your mobile telephone or handheld device (“Device”).
IMPORTANT INFORMATION AND WHO WE ARE
Contact details
Our full details are:
• Full name of legal entity: AYAYDIN MIROGLIO GENERAL TRADING L.L.C
• Email address: personaldata@ipekyol.com.tr ]
• Postal address: Unit FF-120 , First Floor , The Dubai Mall , Dubai , UAE
You have the right to complain to Us if You are concerned about Our handling of Your Data by using the contact details provided herein above.
THE DATA WE COLLECT ABOUT YOU
We may collect, use, store, and transfer different kinds of personal data about you as follows:
• Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
• Contact Data: billing address, delivery address, email address, and telephone numbers.
• Financial Data: bank account and/or payment card details.
• Transaction Data: includes details about payments to and from You.
• Device Data: includes the type of mobile device You use, a unique device identifier, (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, Your mobile operating system, the type of mobile browser You use, time zone setting.
• Content Data: includes information stored on Your Device, including friends’ lists, and login information.
• Profile Data: includes [Your username and password, transaction history, Your interests, preferences, selfie and ID card images, feedback, and survey responses.
• Usage Data: includes details of Your use of any of Our Apps or Your visits to any of Our Website including, but not limited to, traffic data [and other communication data, whether this is required for Our own billing purposes or otherwise [and the resources that You access].
• Marketing and Communications Data includes Your preferences in receiving marketing from Us and Our third parties and Your communication preferences.
• Location Data: includes Your current location disclosed by GPS, or similar technology.
We may also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated data is derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we aggregate your usage Data to calculate the percentage of users accessing a specific website or app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
Third-Party Links
Please note that the Application and Website may, from time to time, contain links to and from the websites of Our partner networks, advertisers, and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before You submit any personal data to these websites or use these services.
HOW IS YOUR DATA COLLECTED?
We will collect and process the following data about You, which shall be collected in the manner as stated herein below:
Information you give us. This information includes Identity, Contact, Financial, and Marketing and Communications Data. You consent to giving us this information about You by filling in forms on the ae.ipekyol.com Website, or by corresponding with us (for example, by email or chat). It includes information You provide when You register to use Website, download or register on the App or access the Website, and when you report a problem with the App, or Website. If you contact Us, we will keep a record of that correspondence.
Information we collect about You and Your Device. Each time You visit one of Our Website or use one of Our apps we will automatically collect personal data including Device, Content, and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
Location Data. We also use GPS technology to determine Your current location. Some of Our location-enabled services require Your personal data for the feature to work. If You wish to use the particular feature, You will be asked to consent to Your location data being used for this purpose. You can withdraw Your consent at any time by disabling Location Data in your settings.
Information We receive from other sources including third parties and publicly available sources. We will receive personal data about You from various third parties and public sources such as:
• analytics providers, advertising networks, or search information providers;
• providers of technical, payment, and delivery services;
• data brokers or aggregators;
• publicly available sources.
COOKIES
We use cookies [and/or other tracking technologies] to distinguish You from other users of the App, Website, the distribution platform (Appstore) and to remember Your preferences. This helps Us to provide You with a good experience when You use the App or browse any of Our Website and also allows Us to improve the App and Website. For detailed information on the cookies We use, the purposes for which We use them, and how You can exercise Your choices regarding Our use of Your cookies, see Our cookie policy
GENERAL PRINCIPLES CONCERNING THE PROCESSING OF THE DATA
At the Company, We aim to abide by the following generally accepted principles which are implemented in relation to the Processing of the Data:
a) The fair, transparent, lawful, and secure Processing of the Data;
b) The Processing of the Data for the specified, clear, explicit, and legitimate purposes in accordance with Your rights. The Data will not be Processed at any time in a manner which is incompatible with the aforesaid purpose. However, it may be Processed if the purpose is similar or close to the purpose for which this data is collected;
c) Not to Process the Data in a way which is incompatible with the purpose for which it was collected or Your rights. However, in some cases, We may demonstrate that We have compelling legitimate grounds to Process Your date which may override Your rights and freedoms;
d) The adequate, relevant, and not excessive Processing of the Data in relation to the purposes for which it is collected and/or further Processed;
e) The Processed Data to be accurate and, where necessary, is kept up to date;
f) The Processed Data is kept in a form that permits Your identification for no longer than is necessary for the purposes for which the Data was collected or for which it was further Processed.
g) To erase or rectify the inaccurate or incomplete Data, having regard to the purposes for which it was collected or for which it is further Processed;
h) Data is kept securely, including protecting it from any violation, penetration, or illegal or unauthorized Processing through the development and use of appropriate technical and organizational measures and procedures in accordance with the laws and legislation in force in this regard; and
i) Data is deleted after the purpose of its Processing has been exhausted. It may be kept if the identity of the Data Subject has been concealed using the "Anonymization Mechanism".
HOW WE USE YOUR DATA
We will only use Your personal data in accordance with the relevant and applicable laws.
Most commonly We will use and Process Your Data in the following circumstances:
• Where You have consented before the Processing of the Data.
• Where Processing is necessary for the Performance of a Contract to which You are a party with us.
• Where we need to use your personal information to provide you with our services.
• Where it is necessary for the legitimate interests pursued by Us or by a Third Party who is authorized to Process the Data and is under our control or the parties to whom the Data is disclosed and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation to which You are a subject.
• Where it is necessary for the performance of a task carried out in the interest of a legal and/or regulatory body or Our exercise of a power of such legal and/or regulatory body vested in Us or in a Third Party who is under our control and is authorized to Process the Data and to whom the Data is disclosed.
Please see below to find out more about the types of Lawful Basis that we will rely on to Process Your Data.
We will only send You direct marketing communications by email or text if we have Your consent.
You have the right to withdraw Your consent to the collection, storage, processing, and usage of Your Data at any time by contacting Us by using Our contact details provided in this Policy.
PURPOSES FOR WHICH WE WILL USE AND PROCESS YOUR DATA
• To install the App and register as a new App user, to access, login, and register to our website
• To manage our relationship with you including notifying you of changes to the App and Website
• To enable you to participate in or complete a survey
• To administer and protect our business and this App and Website including troubleshooting, data analysis, and system testing
• To deliver content and advertisements to you
• To make recommendations to you about the products and services which may interest you
• To measure and analyze the effectiveness of the advertising we serve you
• To monitor trends so we can improve the App
To facilitate the preparation and shipment of orders
To ensure the proper delivery of orders
To comply with legal requirements
DISCLOSURES OF YOUR DATA
When You consent to provide Us with Your Data, You also consent to share Your Data with the third parties set out below for the purposes set out in the section entitled Purposes for which we will use Your Data:
• The following third parties, which may be situated outside the jurisdiction of the incorporation of the Company:
a) any affiliate, subsidiary, or partner of the Company;
b) agents, contractors, service providers, and other third parties who support the Company and are contractually bound to keep the information confidential and only use it for the purposes it is provided to them;
c) where express consent is provided by You for such disclosure;
d) with other third parties with which the Company collaborates for marketing and promotional campaigns, contests, and offers;
e) to a buyer or a successor in the event of a merger, financing, acquisition, restructuring, reorganization, dissolution, bankruptcy, or sale/ transfer of all or part of the Company’s assets, where the Data will be one of the transferred assets;
f) with advertisers and investors for the purpose of conducting general business analysis. We may also share Your information with such third parties for marketing purposes, as permitted by law.
g) to respond to legal Processes, to investigate or remedy potential violations of Our policies, or to protect the rights, property, and safety of others, We may share Your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.; and
h) where such disclosure is required and/or permitted by the applicable laws, regulations, and orders.
You agree that We have the right to transfer the Personal information described in this Policy to and from, and Process and store it in, the United Arab Emirates and (where applicable or required) with the processors in other countries/ jurisdictions, some of which may be less protective privacy laws than those where you reside. Where this is the case, we will take appropriate security measures to protect your Personal information in accordance with this Policy and the relevant data protection laws governing Us.
SOCIAL MEDIA
We operate channels, pages, and accounts on some social media sites to inform, assist, and engage with customers. We monitor and record comments and posts made on these channels about us so that we can improve our services.
We are not responsible for any information posted on those sites other than the information we have posted ourselves.
We do not endorse the social media sites themselves or any information posted on them by third parties.
The following companies, Meta (Facebook, Instagram, Whatsapp) X (also known as Twitter), YouTube, TikTok, Snapchat, Google, Yahoo, and LinkedIn, may use data for their own purposes, specifically to market to you through their social media platforms and allow engagement on our websites. This includes profiling and targeting you with other advertising.
DATA SECURITY
All information You provide to Us is stored on Our secure servers.
Any payment transactions will be encrypted using Secured Sockets Layer or alternative encryption technology as may become relevant in the future. Where we have given You (or where You have chosen) a password that enables You to access certain parts of Our App and/or Website (as applicable), You are responsible for keeping this password confidential. We ask You not to share the password with anyone.
Once We have received Your information, We will use strict procedures and security features and do Our best to prevent Your personal data from being lost, used, or accessed in an unauthorized way. This includes having in place, the appropriate technical and organizational measures to implement the necessary standards to protect and secure You Data in order to preserve its confidentiality and privacy and to ensure that it is not breached, destroyed, altered, or tampered with, taking into account the nature, scope and purposes of Processing and the possibility of risks to the confidentiality and privacy of Your Data. We also have appropriate technical and organizational measures in place, with respect to automatic settings, to ensure that the Processing of Your Data is limited to the purpose for which it is intended.
We have put in place procedures to deal with any suspected personal data breach and will notify You and any applicable regulator when We are legally required to do so.
While we have taken reasonable steps to secure the Data You provide to Us, please be aware that despite Our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security. We shall not be responsible and/or liable for any disclosure of information due to unauthorized third-party access, or other reasons beyond our control. It is important that You do not share your account details, such as your username, password, and security information, with anyone, as it would be assumed that the individual logging in with your account details has the proper authorization to do so.
DATA RETENTION
In some circumstances You can ask us to delete Your data: see below for further information.
In some circumstances, We will anonymize Your Data (so that it can no longer be associated with You) for research or statistical purposes, in which case We may use this information indefinitely without further notice to You.
You may at any time review or change the information in Your account or terminate Your account by:
· Logging into Your account settings and updating Your account
· contacting us using the contact information provided in this Policy
Upon Your request to terminate Your account, We will deactivate or delete Your account and information from Our active databases. However, some information may be retained in Our files to prevent fraud, troubleshoot problems, assist with any investigations, and/or comply with legal requirements.
GLOSSARY
Lawful Basis means Processing Your Data where You have signified Your agreement by a statement or clear opt-in to the Processing of the Data. You can withdraw Your consent at any time by contacting Us.
Legitimate Interest means the interest of the Company in conducting and managing the business to enable Us to give You the best service/product and the best and most secure experience. We make sure We consider and balance any potential impact on You (both positive and negative) and Your rights before We Process Your Data for Our legitimate interests. We do not use Your Data for activities where Our interests are overridden by the adverse impact on You (unless We have Your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on You in respect of specific activities by contacting Us.
Performance of a Contract means Processing Your Data where it is necessary for the performance of a contract to which You are a party or to take steps at Your request before entering into such a contract.
Comply with a legal obligation means Processing Your Data where it is necessary for compliance with a legal obligation that We are subject to.
Process, Processed, Processes and Processing means any operation or set of operations which is performed upon the Data whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
Recipient means any person to whom the Data is disclosed in accordance with the terms of this Policy, whether a Third Party or not; however, authorities which may receive Data in the framework of a particular inquiry shall not be regarded as Recipients.
Third Party means Any person other than You, Us, and the persons who, under the direct control of Us are authorized to Process the Personal Data.
YOUR LEGAL RIGHTS You have the right to:
Under certain circumstances, You have the following rights under data protection laws in relation to Your Data.
You can exercise any of these rights at any time by contacting Us at personaldata@ipekyol.com.tr
• Request access and confirmation in writing to Your Data. This enables You to receive a copy of the Data we hold about You and to check that we are lawfully Processing it. This right also includes the request for information at least as to the purposes of the Processing of Your Date, the categories of Data concerned, and the relevant Recipients or categories of Recipients to whom the Data are disclosed.
• Request correction of the Data that We hold about You. This enables You to have any incomplete or inaccurate Data We hold about You corrected, though We may need to verify the accuracy of the new data You provide to Us. We will endeavour to send a correction notice to the businesses or others to whom We have shared the inaccurate Data (“Notified Parties”), where required and/or appropriate. However, We cannot be held liable for the failure of such Notified Parties to update or correct Your Data. Some third parties and third-party sites may continue to process inaccurate Data about You until their databases and display of data are refreshed in accordance with their update schedules, or until You contact them personally to ensure the correction is made in their own files.
• Request erasure of Your Data. This enables You to ask Us to delete or remove Your Data where there is no good reason for Us continuing to process it. You also have the right to ask Us to delete or remove Your Data where You have successfully exercised Your right to object to Processing (see below), where We may have Processed Your information unlawfully, or where We are required to erase Your Data to comply with local law. Note, however, that We may not always be able to comply with Your request for erasure for specific legal reasons which will be notified to You, if applicable, at the time of Your request.
• Object to Processing of Your Data where We are relying on a Legitimate Interest (or those of a Third Party) and there is something about Your particular situation which makes you want to object to Processing on this ground as You feel it impacts on Your fundamental rights and freedoms. In some cases, We may demonstrate that We have compelling legitimate grounds to process Your information which overrides Your rights and freedoms.
• Request restriction of Processing of Your Data. This enables You to ask Us to suspend the Processing of Your Data in the following scenarios:
a) if You want Us to establish the Data’s accuracy;
b) where Our use of the Data is unlawful but You do not want Us to erase it;
c) where You need Us to hold the Data even if We no longer require it as You need it to establish, exercise, or defend legal claims; or
d) You have objected to Our use of Your Data but We need to verify whether We have overriding legitimate grounds to use it.
• Request the transfer of Your Data to You or to a Third Party chosen by You. We will provide to You, or the said Third Party, Your Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that You initially provided consent for Us to Use or where We used the information to perform a contract with You.
• Request to be informed and object to the disclosure of Your Data to third parties before the Data is disclosed for the first time to Third Parties or used on their behalf for direct marketing, and to be expressly offered the right to object to such disclosures or uses.
• Withdraw consent at any time when We are relying on consent to process Your Data. Once You provided consent to the Processing of the Data by selecting “YES”, You may, by providing reasonable grounds, withdraw said consent at any time thereafter by contacting Us [Link to CONTACT DETAILS]. However, this will not affect the lawfulness of any Processing of the Data carried out before You withdraw Your consent. If You withdraw Your consent, We may not be able to provide certain products or services to You. We will advise You if this is the case at the time You withdraw Your consent.
GOVERNING LAWS AND DISPUTE RESOLUTION
The terms of this Policy are governed by the laws of the United Arab Emirates and any action arising out of or in relation to this Policy, shall fall under the exclusive jurisdiction of the courts of the Dubai and You exclusively and irrevocably consent to the jurisdiction of said court.
