At Silkway Cosmetic, protecting your personal information is our top priority. This Privacy Policy explains how we collect, use, store, and share your data. It is designed to comply with Turkey’s KVKK law, as well as international standards such as the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). By using our website and services, you agree to the practices outlined here.

Key Definitions

To clarify legal terms and ensure transparency:

1. Personal Data: Any information that identifies you directly or indirectly (e.g., name, email, address).
2. Data Controller: Silkway Cosmetic, responsible for determining the purposes and means of processing your data.
3. Processing: Any operation performed on personal data, including collection, storage, and sharing.

Data Collection Methods

We collect your data through the following means:

1. Direct Interactions:
   • When you fill out forms on our website.
   • When you contact us via email or phone.
   • When you make a purchase or request a service.
2. Automated Technologies:
   • Cookies and tracking technologies used on our website.
   • Analytics tools for tracking website performance.
3. Third Parties:
   • Payment processors.
   • Advertising platforms (e.g., Meta, Google).

Legal Basis for Data Processing (GDPR & KVKK Compliance)

We process your personal data on the following legal grounds:

1. Consent: When you explicitly consent to marketing or data sharing.
2. Performance of a Contract: When processing is necessary to fulfill orders or services.
3. Legal Obligation: To comply with regulatory requirements.
4. Legitimate Interest: For business analytics, fraud prevention, or website improvements.

Data We Collect

Personal Data

• Name, surname, and title.
• Contact details (phone, email, address).
• Billing and shipping information.

Non-Personal Data

• Browser type, operating system, and device information.
• IP address and geolocation.
• Behavioral data (e.g., pages viewed, time spent on website).

Sensitive Data (if applicable)

• For KVKK, additional protection measures will apply to sensitive data, such as financial details or health-related information, if collected.

Purpose of Data Processing

We use the data we collect for:

1. Order Fulfillment: To deliver products and provide services.
2. Marketing: To send promotional offers, newsletters, and updates (with consent).
3. Website Optimization: To enhance user experience and site performance.
4. Compliance: To meet legal and regulatory requirements in Turkey and abroad.

Your Rights (GDPR & KVKK)

As a user, you have the following rights:

1. Access: Request access to the personal data we hold about you.
2. Correction: Rectify inaccurate or incomplete data.
3. Erasure: Request the deletion of your data, where legally permitted.
4. Restriction: Limit the processing of your data.
5. Objection: Object to data processing based on legitimate interests or direct marketing.
6. Data Portability: Receive a copy of your data in a commonly used format.

How to Exercise Your Rights:

• Email us at privacy@silkwaycosmetic.com.

Data Sharing and International Transfers

1. Third-Party Services:
   • Shipping companies for order deliveries.
   • Payment gateways for secure transactions.
2. Cross-Border Transfers:
   • Data may be transferred to servers outside Turkey, including the EU and the USA, under strict safeguards like Standard Contractual Clauses (SCCs).

Security Measures

1. Technical Measures:
   • SSL encryption for secure communication.
   • Regular vulnerability assessments and penetration testing.
2. Organizational Measures:
   • Restricted access to data by authorized personnel only.
   • Training for employees on data protection laws and practices.

Data Retention Policy

• Personal data is retained for as long as necessary to fulfill the purposes outlined in this policy or as required by law.
• After the retention period, data is securely deleted or anonymized.

Use of Cookies and Analytics

1. Cookie Types:
   • Essential cookies for website functionality.
   • Performance cookies for analytics and optimization.
   • Marketing cookies for personalized ads.
2. Cookie Management:
   • Users can manage preferences via the cookie banner or browser settings.

Children’s Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal data from children.

Updates to This Policy

This Privacy Policy is subject to change to comply with evolving laws or operational requirements. The latest version will always be available on this page, and significant changes will be communicated via email or website notifications.

Additional Compliance Notes for Turkey and International Markets

• KVKK Notifications:

  • Users will be informed of their rights and how to file complaints with Turkey’s Personal Data Protection Authority (KVKK).
  • Contact details of the KVKK will be provided for Turkish users.

• GDPR Compliance:

  • Detailed data protection impact assessments (DPIAs) will be conducted for all data processing activities involving high risks.
  • The appointment of a Data Protection Officer (DPO) may be considered if required for EU operations.

• CCPA Compliance:

  • Inclusion of a “Do Not Sell My Personal Information” link for California users.
  • Explanation of CCPA-specific rights like opting out of data sales.