Last updated October 28, 2022
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SUMMARY OF KEY POINTS
What personal information do we process? When you visit, use or navigate our Services, w emay process personal information depending on how you interact with Cleopatra Ink and the Services, the choices you make, and the products and features use. You can also check “ Personal Information Provided by You:” to learn more.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any informantion from third parties? W emay receive information from public databases, marketing partners, social media platforms, and other outside sources. You can also check “ Information authomatically collected” to learn more.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. You can also check “HOW DO WE PROCESS YOUR INFORMATION?” to learn more.
In what situation and with which partşes do we share personal information? We may share information in specific situations and with specific third parties (our business partner and our Franchisee’s). You can also check “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” to learn more.
How do we keep your information safe? We ahve organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage techonology can be guaranteed to 100% secur, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, Access, steal or modfiy your information. You can also check “HOW DO WE KEEP YOUR INFORMATION SAFE?” to learn more.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean have certain rights regarding your personal information. You can also check “WHAT ARE YOUR PRIVACY RIGHT” to learn more.
How do you exercise your rights? The easiest way to exercise your rights is to contacting us by sending an e-mail to [email protected]. We will consider and act upon any request in accordance with the data protection law.
Want to learn more about what Celopatra Ink does with any information we collect? You can also check “WHAT INFORMATION DO WE COLLECT?” to learn more.
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE PROCESS YOUR INFORMATION?
- WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
- WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- HOW DO WE HANDLE YOUR SOCIAL LOGINS?
- IS YOUR INFIRMATION TRANSFERRED INTERNATIONALLY?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- HOW DO WE KEEP YOUR INFORMATION SAFE?
- WHAT ARE YOUR PRIVACY RIGHT?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHT?
- DO WE MAKE UPDATES TO THIS POLICIY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
- HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide us when you register on the Services, Express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You: The person information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- Phone numbers
- Email addresses
- Mailing addresses
- Contact preferences
- Contact or authentication data
Sensitive Information: We do not process sensitive information.
Social Media Login Data: W emay provide you with the option register with us using tyour existing social media account details, like your Facebook, Twitter, or other social media account described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.
All personal information that you provide to us must be true, complete and accurate and you must notify us od any changes to such personal information.
Information authomatically collected
In Short: Some information – such as your Internet Protocol (IP) address and/or browser and device characteristic – is collected automatically when you visit our Services.
When automatically collect certain infromation when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information about how and when you use our Services, and other techinical information. This information is primarily need to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses , we also collect information through cookies and similer Technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers authomatically collect when Access or use our Services and which we record in log files. Depending on how you interact with us, this log datamay include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searcches, and other actions you take suh as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to Access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browrser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type amd settings of the device you use to Access the Services. For example, we may use GPS and other Technologies to collect geolocation data that tell us your current location( based on your IP address). You can opt out of allowing us to collect this information either by refusinf Access to the information or by disabling your Location setting on yourdevice. However, if you choose to opt out, you may not able to use certain aspects of the Services.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
In orderto enchance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URL’s, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.
- HOW DO WE PROCESS YOUR INFORMATION
In Shorts : We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and oterwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To respond to user inquiries/offer support to user. We may peocess your information to respond to your inquiries and solve any potential issues you might have with the requested services.
- To administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar informaiton.
- To fulfill and manage your orders. W emay process your infromation to fulfill and manage your orders, payments, returns, and exchanges madprocesse through the Services.
- To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allows for communication with another user.
- To request feedback. We may process yoru infromationwhen necessary to request feedback and to contatc you about your use of our Services.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more informaiton, see “WHAT ARE YOUR PRIVACY RIGHTS?” below.
- To deliver targeted advertising to you. We may process your information develop and displeay personalized content and advertising tailored to your interests, location, and more.
- To protect our Services. W emay process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and preventation.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To determine the effectiveness of our marketing and promotional campaigns. We may process your informaiton to better understand how to provide marketing and promotional campaigns that are most relevant to you.
- To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
- WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Shorts: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligation, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your informaiton. As such, w emay rely on the following legal bases to process your personal informaiton.
- Consent: We may process yoru information if you have given us permission (i.e., consent) to use your personal information for a specific purposes. You can withdraw your consent at any time. For more informaiton, see “WHAT ARE YOUR PRIVACY RIGHTS” below
- Performance of Contract: We may process your personal informaiton when we believe it is necessary to fulfill our contractual obligaitons to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legimate business interests and those interests do not outweigh your interests and fundamental rights abd freedoms. For example, w emay process your personal information for some of the purposes described in order to:
- – Send users informaiton about special offers and discounts on our products and services.
- – Develop and display personalized and relevant advertising content for our users
- – Analyse how our Services are used so we can improve them to engage and retain users
- – Support our marketing activities
- – Diagnose problems and/or prevent fraudulent activities
- – Understand how our users use our products and services so we can improve user experience
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligaitons, such as the cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your informaiton as evidence in litigaiton in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital insterests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this Section applies to you.
We may process your information if you given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations whre your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. For more informaiton, see “WHAT ARE YOUR PRIVACY RIGHTS” below
In some exceptioanl cases, w emay be legally permitted under applicable law to process your informaiton without your consent, including, for example:
- If you collection is clearly in the interests of individual and consent cannot be obtained in a timely way
- For investigatons and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in awitness statement and the collection is necessary to assess, process, or settle an insurance
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is or nmay be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accurancy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena warrant, court order, orrules of the court relating to the production of records.
- If it was produced by an individial in the course of their employment, business or profession and the collection is consistent with the purposes for which the infromation was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the informaitonis publicly available and is specified by the regulaitons
- WHEN AN WITH WHOM DO WE SAHRE YOUR PERSONAL INFORMATION
In Shorts: We may share informaiton in specific situations described in this section and/or with the following parties.
We may need tos hare your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of compant assets, financing, or acquisition of al lor a portion of our business to another company.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
- HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Shorts: If you choose to register or log in to our Services using a social media account, we may have Access to certain informaiton about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile Picture, as well as other informaitonyou choose to make public on such a social media platform.
- IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Shorts: We may transfer, store, and process your information in countries other than your own.
Our servers are located in Turkey. If you are accessing our Services from outside Turkey, please be aware that your informaiton may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see” WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION ?“ above), in Turkey, and other countries.
European Commission’s Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses required all recipients to protect all personal information that theyprocess originating from the EEA and UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and futher details can be provide upon request.
- HOW LONG DO WE KEEP YOUR INFORMATION
We have nı ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
- HOW DO WE KEEP YOUR INFIRMATION SAFE
In Shorts: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. How ever, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be %100 secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and imporperly collect, access, steal, or modify yoru information. Although we will do our best to protect your personal information tarnsmission of personal infromation to and from our Services is at your own risk. You should only Access the Services with a secure environment.
- WHAT ARE YOUR PRIVACY RIGHTS
In Shorts: In some region, such as European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that alow you greater Access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request Access and obtain a copy of ypur personal information, (ii) to request rectification or erasure; (iii) to restrict the processinfg of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have right to object to the processing of your personal information. You can make such a request by contacting us by using the contact detaşls provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:
If youe are located in Switzerland, the sontact details fort eh data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” belowor updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubcribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below. You will then be removed from the marketing lists. However, we may still communşcate with yot- for example, to send you service-related messages that are necessary for the administration and use ıf your account, to respond to service requests, or for other non-marketing purposes.
If you would at any time like to review or change the information in your account or terminate your account, you can:
- – Contact us using contact information provided.
- – Log in to your account settings and update your users account.
Upon your requets to terminate your account, we will deactive or delete your account and information from our active databases. However, w emay retain some information in our files to prevent fraud, troubleshoot problems, assit with any investigation, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/
If you have any questions or commnets about your privacy rights, you may emial us at [email protected].
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIHGTS?
In Shorts: Yes, if you are resident of California, you are granted specific rights Access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are Clifornia residents to request and obtain from us, once a year and free of charge, information about categories of personal informaiton (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the imddediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If youe are under 18 years of age, reşide in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement taht you reşide in California. We will make sure the dat is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
- – Every individual who is in the State of California for other than a temporary or transitory purposes and,
- – Every individual who is domiciled in the Satet of California who is outside the Satet of California for a temporary or transitory purposes
All other individuals are defined as “non-residents”.
If this defination of “ resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We Have collected the following categories of personal information in the past 12 (twelve) months:
Contract detaşls, such as real name, alias, postal address, telephone or mobile contact number, unique peronal identifier, online identifier, Internet Protocol (IP) address, email address, and account name
B. Personal Information categories listed in the California Customer Record Statute
Name, contact information
Education, employment, employment history, and financial information
C. Protected clessification characteristics under California of Federal Law
Gender and date of birth
D. Commercial Information
Transaction information, purchase history, financial details, and payment information
E. Biometric Information
Fingerprints and voiceprints
F. Internet or similar network activity
Browsing history, search history, online behaviour, interest data, and interactions wiht our and other websites, applications, systems, and advertisements
G. Geolocation data
H. Audio, electronic, visiual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities
I. Professinal or employment-related information
Business contact details in order to provide you our Services at a business level or job title, work history, and Professional qualifications if you apply for a job with us
J. Education Information
Student records and directory information
K. Inferences draw from other personal information
Inferences draw from any of collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characterictics.
We may also coolect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- – Receiving help through our customer support channels;
- – Participation in customer surveys or contests; and
- – Facilitation in delivery of our Services and to repond to your inquiries.
How do we use and share your personal information?
You may contact us by email at [email protected], Live Chat, Whatsapp, or by reffering to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out w emay deny a request if the authorizaed agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal infromation for our own business purposes, such as for undertaking internal research for technological development and demonstartion. This is not considered to be “ selling” of your personal information.
Karadere Turizm Organizasyon LLC has not disclosed or sold any personal infromation to third parties for a business or commercial purpose in the preceding twelve (12) months. Karadere Turizm Organizasyon LLC has not disclosed or sold any personal informaiton in the future belonging to website, visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data – Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements result from legal obligation, or any processing that may be required to protect against illegel activities.
Right to be informed – Request to know
Depending on the circumstances, you have a rigth to know:
- – whether we collect and use your personal information;
- – the categories of personal information that we collect;
- – the purposes for which the collected personal information is used;
- – whether we sell your personal information to third parties;
- – the categories of personal information that we sold or disclosed for business purpose;
- – the categories of third part parties to whom the personal information was sold or disclosed for a business purpose; and
- – the business or commercial purpose for collecting or selling personal information
In accordance with appliacble law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumet request.
Right to Non-Discrimination for Execrcise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will need to verify yoru identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain inforamtion so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methdos as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to maket he request. To extent possible, we will avoid requesting additional information from you fort he purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may requets that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
- – You may object to the processing of your personal information.
- – You may requets correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
- – You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
- – You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission
To exercise these rights, you can contact us by email at [email protected] , Live Chat, Whatsapp, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
- DO WE MAKE UPDATES TO THIS NOTICE?
In Shorts: Yes, we will update this notice as necessary to stay compliant with relevant laws.
- HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this policy, you may contact our Data Protection Officer, by email at [email protected], or by post to:
Karadere Turizm Organizasyon LLC
Dinek Mh. Emirgan Bul. Sosyal Tesis Blok No:23/1A 07400 Alanya Antalya Turkiye
- HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request Access to the personal information we collect from you, cahnge that information, or delete it. To request to review, update or delete your personal information, please send an e-mail to [email protected]