Privacy Policy

*PRIVACY AND COOKIE POLICY* 1. Lahora Saat ve Kuyumculuk Tic. A.Ş. (“LAHORA”), as the data controller, processes certain personal data (Identity Information, Contact Information, Address and Location Information, Request and Complaint Information, Legal Transaction Information, Marketing Information) of individuals (“Users”) who use or visit the website at ……………… (“Website”) to provide better service, facilitate the use of our products and services, and ensure communication with individuals affiliated with our company. The data collected through the Website is used, stored, and retained in compliance with the principles of personal data protection and privacy. 2. LAHORA does not share information provided and entered by users through forms on the Website with third parties without users’ knowledge or consent, except as stated in established policies and information texts. The company does not use this information for purposes other than its business activities and undertakes not to transfer it to third parties for commercial purposes. 3. LAHORA uses first-party and third-party cookies provided by third-party suppliers (such as search engines) to block harmful content and unwanted advertisements. 4. Processed and stored personal data will only be shared with relevant public institutions and authorities upon request and in compliance with applicable mandatory legal provisions, provided that the explicit consent of the individual is required and obtained. 5. By approving this privacy policy, Users acknowledge that the information provided belongs to them, was entered by them, and can be shared with relevant individuals for the limited purposes outlined in policies concerning job application processes, communication, and sales and marketing activities. 6. Users who accept the use of the Website are deemed to have read and agreed to all terms of this Policy, been informed about the processing of their personal data, and expressly consented to its processing within the defined scope and purposes. 7. LAHORA reserves the right to amend this Privacy Policy without prior notice in accordance with legislative changes, organizational modifications, decisions by the Personal Data Protection Board, or emerging new conditions. Users can submit their requests regarding personal data using the “Application Form” provided by the company. 8. Users may be directed to other websites or social media platforms through links on the Website. When clicking on such links, it is important to review the privacy policies of the respective sites, as LAHORA is not responsible for the content or policies of third-party websites. The company has no control or liability over such external sites. 9. It is a well-known and declared fact by IT experts and international authorities that it is impossible to guarantee “100% secure protection” of personal data on the internet. While our company takes all necessary administrative and technical measures to protect personal data, we cannot fully guarantee the security of data transmitted via our Website. 10. LAHORA has established the necessary policies for processing, protecting, storing, and deleting personal data in compliance with regulations. The company declares that it will not disclose personal data or share it with third parties except as stated in the policies, in adherence to the principle of confidentiality. The obligation of confidentiality regarding personal data continues even after the termination of employment contracts with employees, and non-compliance with legal obligations may result in the termination of employment contracts for just cause and the application of necessary sanctions. --- ### *WEBSITE COOKIE POLICY* LAHORA, as the data controller, uses various cookies to ensure the smooth operation and functionality of the …………….. Website. Personal data is processed in compliance with the “Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data” (Convention 108), signed in Strasbourg on January 28, 1981, by the Council of Europe, and the Turkish Personal Data Protection Law No. 6698. When visiting the Website, Users may encounter third-party cookies from external websites. LAHORA does not have control over these third-party cookies. #### *Processed Personal Data* As outlined in this policy, certain personal data is automatically processed depending on Users’ access and online activities on the Website. These include: - Internet Protocol (IP) Address - User ID Number - Online Browsing/Transaction Information - Browser Type and Language Preferences - Operating System (e.g., Windows, macOS, Android, iOS) - Internet Service Provider (ISP) - Date/Time Stamp of Internet Access - Referring Website URL - Domain Name of Internet Provider - Computer MAC Address (Media Access Control Address) If membership, contact, or other forms are filled out on the Website, additional personal data such as identity information, contact details, transaction and security data, legal information, marketing information, and request/complaint data may also be processed. --- ### *PURPOSES OF PERSONAL DATA PROCESSING* This Cookie Policy serves as an information notice, explaining how personal data obtained through cookies on the Website is processed. Cookies are used for the following purposes: - Ensuring the core functionalities of the Website operate correctly - Analyzing and improving the performance of the Website - Identifying the number of visitors and their interactions with the Website - Enhancing user experience and facilitating functionality - Enabling sharing via third-party social media platforms Users can control and manage cookies through their browser settings. LAHORA reserves the right to modify this policy at any time, with updates announced via the Website or other designated methods. --- ### *METHODS AND LEGAL BASIS FOR PERSONAL DATA COLLECTION* Users' personal data is collected electronically through cookies during their Website visits, based on: - The legitimate interests of the company - The establishment and execution of contracts with relevant individuals - Compliance with legal obligations under Turkish Personal Data Protection Law No. 6698 Personal data is processed, collected, and transferred as outlined in this policy. --- ### *DATA TRANSFERS TO THIRD PARTIES AND ABROAD* Personal data may be shared with employees, company executives, business partners, suppliers, service providers, IT support providers, and authorized public institutions in compliance with regulations. Additionally, personal data may be stored on domestic or international servers and transferred abroad in compliance with the relevant legal framework, including transfers outside the European Union. LAHORA guarantees that personal data will not be shared with third parties for commercial purposes without prior information or explicit consent from the data owner. --- ### *USER RIGHTS UNDER THE PERSONAL DATA PROTECTION LAW* Under Article 11 of the Turkish Personal Data Protection Law No. 6698, Users can submit their requests regarding their personal data by completing the company’s “Application Form.” --- ### *WHAT ARE COOKIES?* Cookies are small text files stored on a user's device by a website. They allow the website to remember preferences and recognize the device on future visits. Cookies are essential components of internet technology and are widely used across nearly all websites. #### *Types of Cookies Used on the Website* - *Mandatory Cookies:* Essential for the Website’s functionality; do not process personal data. - *Performance Cookies:* Measure and improve Website performance; collect anonymized data. - *Functionality Cookies:* Remember user preferences, such as language or location settings. - *Marketing/Targeting Cookies:* Track user activity across websites to deliver targeted advertising. --- ### *HOW TO MANAGE COOKIE PREFERENCES?* Users can enable or disable cookies via browser settings: - *Google Chrome:* Click the lock or “i” icon in the address bar → “Cookies” settings - *Internet Explorer:* “Tools” → “Security” → Manage cookie permissions - *Mozilla Firefox:* “Open Menu” → “Options” → “Privacy & Security” settings - *Safari:* “Settings” → “Safari” → “Privacy & Security” settings For detailed cookie management, visit [www.allaboutcookies.org](https://www.allaboutcookies.org) or [www.aboutcookies.org](https://www.aboutcookies.org). --- This document outlines LAHORA’s commitment to privacy and compliance with data protection laws. Users who continue to browse the Website acknowledge and accept the policies stated above