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Privacy and Personal Data Protection Policy

SADRAZAM HEDİYELİK EŞYA İTH. İHR. SAN. VE TİC. LTD. ŞTİ.
Privacy and Personal Data Protection Policy

This Policy has been prepared to inform data subjects about the personal data processing activities carried out by Sadrazam Gifts in accordance with Turkish Personal Data Protection Law No. 6698.

Last Updated: August 11, 2026

Sadrazam Hediyelik Eşya İth. İhr. San. ve Tic. Ltd. Şti. (“Sadrazam Gifts”, “Sadrazam” or the “Company”) attaches importance to the privacy and security of personal data.

Personal data is processed lawfully and fairly; kept accurate and, where necessary, up to date; processed for specified, explicit and legitimate purposes; and limited to what is relevant, necessary and proportionate to those purposes.

Important Notice

This document is a privacy and information notice. Reading or viewing this Policy, or merely using the website, does not constitute explicit consent to the processing of personal data. Where explicit consent is legally required for a particular processing activity, such consent will be obtained separately and specifically for that activity.

1. Data Controller

For the purposes of Turkish Personal Data Protection Law No. 6698 (“KVKK”), the data controller responsible for your personal data is:

Registered Company Name Sadrazam Hediyelik Eşya İth. İhr. San. ve Tic. Ltd. Şti.
Brand Name Sadrazam Gifts
Website www.sadrazamhediyelik.com
Address Kumburgaz Mah. Sade Sk. No:4/A, 34530 Büyükçekmece / İstanbul, Türkiye
Email info@sadrazamhediyelik.com
2. Categories of Personal Data We May Process

Depending on the nature of your interaction with us, including visiting our website, creating an account, placing an order, applying for a wholesale account or contacting us, we may process the following categories of personal data:

Data Category Examples
Identity Information First name, last name and, where required for a particular transaction by applicable law, other necessary identification information.
Contact Information Email address, telephone number, delivery address and billing address.
Customer and Order Information Order number, products ordered, quantities, order date, delivery information, payment method, return and exchange records.
Account and Membership Information Customer account, membership status, customer group, account preferences and account usage records.
Transaction Security Information IP address, connection and transaction logs, technical device and browser information, and security records.
Requests and Communications Product enquiries, contact forms, support requests, complaints and correspondence with us.
Preference and Usage Information Cookie preferences and, where the applicable legal conditions are met, analytics, marketing and commercial communication preferences.
Financial and Transaction Information Transaction records required for payment processing, invoicing, accounting and financial administration.

We do not ordinarily request special categories of personal data as part of the normal use of our services. Please do not provide sensitive personal data unless it is genuinely required for a specific transaction and there is an appropriate legal basis for doing so.

3. Purposes of Processing Personal Data

Depending on the nature of the relevant transaction, your personal data may be processed for the following purposes:

  • Creating and managing customer accounts and memberships,
  • Receiving and processing orders,
  • Preparing, invoicing and delivering products,
  • Processing and monitoring payments,
  • Managing returns, exchanges and after-sales services,
  • Responding to customer enquiries, requests and complaints,
  • Managing wholesale customer applications and commercial relationships,
  • Carrying out accounting, finance and statutory record-keeping activities,
  • Ensuring the security of our website and customer accounts,
  • Preventing fraud, misuse and unauthorised transactions,
  • Complying with our legal obligations,
  • Managing legal disputes and protecting our legal rights,
  • Responding to lawful requests from authorised public authorities,
  • Conducting analytics and service improvement activities where the applicable legal conditions are met,
  • Conducting marketing and commercial communication activities where the required permissions have been obtained.
4. Legal Bases for Processing Personal Data

Personal data is processed under one or more of the legal grounds provided for under the KVKK, depending on the nature of the relevant processing activity.

Where personal data may lawfully be processed on a legal basis other than explicit consent, separate consent will not be requested for the same processing activity.

5. Methods of Collecting Personal Data

Personal data may be collected through registration, order, contact and application forms on our website; customer accounts; ordering and payment processes; email and other communication channels; and technical records and cookies generated during your use of the website.

Personal data may be processed through automated means or through non-automated means provided that such processing forms part of a data filing system.

For further information about our use of cookies, please see our Cookie Policy.

6. Disclosure and Transfer of Personal Data

Personal data may be shared with third parties only to the extent necessary to provide the relevant service, comply with legal obligations or fulfil the purposes described above.

Recipient Category Purpose of Transfer
Shipping and Logistics Providers Delivery of orders to customers.
Banks and Payment Service Providers Secure processing and monitoring of payments.
Technical Service Providers Hosting, software, security, email and technical infrastructure services.
Accounting and Professional Advisers Accounting, financial consultancy, legal services and similar professional services.
Authorised Public Authorities Compliance with statutory obligations and lawful requests made by competent authorities.
Analytics and Marketing Service Providers Analytics and marketing activities where the applicable legal conditions are met and, where required, explicit consent has been obtained.
7. International Transfers of Personal Data

Where certain technology, cloud infrastructure, email, security, analytics or similar services used by us are provided through systems located outside Türkiye, an international transfer of personal data may occur.

Any such transfer is carried out in accordance with Article 9 of the KVKK and only where an applicable lawful international transfer mechanism is available.

Depending on the circumstances, such mechanisms may include an adequacy decision, appropriate safeguards provided for under applicable legislation, standard contracts, or other lawful transfer mechanisms recognised by Turkish data protection legislation.

8. Cookies and Similar Technologies

Strictly necessary cookies may be used to enable the essential functions of our website.

Non-essential cookies used for functionality, analytics or marketing purposes are used subject to the applicable legal requirements and, where necessary, the user's preferences.

Where cookies rely on explicit consent, such cookies are not activated before the user's relevant preference has been obtained. Users may subsequently modify or withdraw their cookie preferences.

For further information, please review our Cookie Policy.

9. Commercial Electronic Communications

Promotional messages, campaign announcements, product notifications and similar commercial electronic communications are carried out in accordance with Turkish Law No. 6563 on the Regulation of Electronic Commerce and other applicable legislation.

Where prior approval is legally required for commercial electronic communications, such approval is obtained separately. Any permission granted for commercial electronic communications may be withdrawn using the methods provided under applicable law.

10. Retention, Deletion and Destruction of Personal Data

Personal data is retained for as long as necessary for the purpose for which it was processed and for any applicable statutory retention periods.

Where the reasons requiring the processing of personal data cease to exist and there is no other legal obligation requiring continued retention, personal data is deleted, destroyed or anonymised in accordance with applicable legislation.

11. Security of Personal Data

Sadrazam Gifts implements appropriate technical and organisational measures, taking into account the nature of the personal data and associated risks, in order to prevent unlawful processing of personal data, prevent unauthorised access and ensure that personal data is securely maintained.

If a personal data breach occurs, the necessary actions are taken in accordance with applicable legislation and the procedures established by the competent authorities.

12. Your Rights Under the KVKK

Under Article 11 of the KVKK, data subjects may, where the applicable conditions are met, exercise the following rights:

  • To learn whether personal data concerning you is being processed,
  • To request information where your personal data has been processed,
  • To learn the purpose of processing your personal data and whether it is being used in accordance with that purpose,
  • To know the third parties to whom your personal data has been transferred within Türkiye or abroad,
  • To request correction where your personal data has been processed incompletely or inaccurately,
  • To request deletion or destruction of your personal data where the legal conditions are met,
  • To request that correction, deletion or destruction operations be notified to third parties to whom your personal data has been transferred,
  • To object to a result arising against you through the analysis of processed data exclusively by automated systems,
  • To claim compensation where you suffer damage as a result of the unlawful processing of your personal data.
13. Applications to the Data Controller

You may submit requests concerning your rights under the KVKK to Sadrazam Gifts using one of the application methods permitted by applicable legislation and by providing sufficient information to enable verification of your identity.

Applications will be evaluated as soon as possible and within the period prescribed by applicable legislation, depending on the nature of the request.

Data Controller Application and Contact Details

Data Controller:
Sadrazam Hediyelik Eşya İth. İhr. San. ve Tic. Ltd. Şti.

Address:
Kumburgaz Mah. Sade Sk. No:4/A, 34530 Büyükçekmece / İstanbul, Türkiye

Email:
info@sadrazamhediyelik.com

14. Updates to This Policy

This Privacy and Personal Data Protection Policy may be updated to reflect changes in applicable legislation, our personal data processing activities, technologies used by the Company or our business processes.

The current version of this Policy and its latest update date will be published on this page.

This Policy provides general information regarding personal data processing activities carried out through the Sadrazam Gifts website and related e-commerce operations. Where a particular processing activity requires a separate privacy notice, explicit consent statement or other specific disclosure, the relevant specific document will apply.