Privacy Policy

Thank you for your interest in our website. The protection of your privacy is very important to us. Below we inform you in detail about how we handle your data.

Our approach to data protection

Koç Deri ve Kuyumculuk A.Ş. is established in Türkiye, and this website, our stores and our
advertising are all operated from Türkiye. The law governing our processing of personal data
is therefore the Turkish Personal Data Protection Law No. 6698 (“KVKK”).

We have chosen to go further than Turkish law requires. Where the European Union’s General
Data Protection Regulation (“GDPR”) sets a higher standard, we apply that standard
voluntarily, and we grant our visitors the equivalent rights described in section 13.
References to the GDPR in this policy describe a commitment we have made, not an obligation
imposed on us.

Data controller

The controller responsible for the processing described in this policy is:

Koç Deri Kuyumculuk Ticaret A.Ş.
Molla Fenari, Tavuk Pazarı Sk. No: 27
34126 Fatih / İstanbul, Türkiye
Telephone: +90 (0) 212 527 55 53
Email: [email protected]

1. Access data and hosting

You can visit our website without providing any personal information. Each time the website
is accessed, the web server automatically saves a server log file, which may contain the name
of the requested file, your IP address, the date and time of access, the amount of data
transferred, and the requesting provider (access data), documenting the access.

This access data is evaluated exclusively to ensure trouble-free operation of the site and
to improve our services. All access data is deleted no later than seven days after your
visit.

A third-party provider provides hosting and presentation services on our behalf. All data
collected via this website is processed on their servers within the European Union or the
European Economic Area.

2. What this website does

This website presents our company, our stores, and our monthly Selections. It is not
an online shop.
You cannot place an order, create a customer account, or make a
payment here.

The pieces shown in our Selections are held in our physical stores in Istanbul. Because each
piece is individual and our stock changes continuously, we cannot guarantee that an item shown
on this website is still available when you visit. We recommend contacting us before you
travel, so that we can confirm availability and prepare a selection for you.

3. Contacting us

You may contact us through our contact form, by email, by telephone, via WhatsApp, or
through our social media channels — for example to enquire about a piece you have seen in a
Selection, or to tell us when you plan to visit.

We collect and use the personal data you provide — typically your name, contact details and
the content of your message — solely to respond to your enquiry and to communicate with you
about it. Mandatory fields in our contact form are marked as such.

Legal basis: taking steps at your request prior to entering into a contract,
or the performance of a contract; and, where your enquiry does not concern a contract, our
legitimate interest in responding to enquiries addressed to us.

We keep enquiry correspondence for as long as necessary to deal with your enquiry and any
follow-up, and thereafter for the periods required by tax and commercial law.

4. Communication via WhatsApp

You can contact us via WhatsApp for enquiries, support, or communication about a purchase.
When you initiate a chat with us, we may collect and store your WhatsApp phone number, your
messages, and any other personal data you provide during the conversation.

Purpose: to respond to your enquiries, provide support, arrange purchases,
and improve our service.

Legal basis: your explicit consent, which you provide by initiating contact
via WhatsApp. You may withdraw your consent at any time.

Storage and retention: your number and messages are stored in our customer
communication systems and are accessible only to authorised personnel. Data is retained for as
long as necessary for the purpose for which it was collected, or as required by law.

WhatsApp is provided by WhatsApp Ireland Limited. Please note that we cannot control how
WhatsApp itself processes data; please see WhatsApp’s own privacy policy for that.

5. Distance sales and shipping

Most of our sales are concluded in person, in our stores. Occasionally, following an
enquiry, a sale is concluded remotely. In that case we process the data necessary to complete
the sale and to deliver the item — typically your name, delivery address, contact details, and
details of the purchase. The legal basis is the performance of a contract.

Where a sale is concluded remotely, we agree the method of payment with you directly, and
process only the data necessary to complete it.

For international delivery we use DHL Worldwide Express Taşımacılık ve Ticaret
A.Ş.
, Yalçın Koreş Cd. No: 20, 34212 Bağcılar/İstanbul, Türkiye. We pass on only the
data DHL needs to deliver your item, which may include your email address and telephone number
for delivery notification.

We also use an external merchandise management system to record sales and stock. That
provider processes data on our behalf, as our processor.

6. Cookies

We use cookies and similar technologies to make your visit attractive, to enable certain
functions, and — where you consent — to measure the effectiveness of our advertising.

You can manage your choices at any time using the cookie settings link in the footer of
every page, or in your browser settings.

  • Strictly necessary. Required for the website to function — session
    handling, security, and storing your cookie preferences. These rest on our legitimate
    interest in operating a secure website and cannot be switched off.
  • Statistics. See section 7. Our analytics tool sets no cookies and
    requires no consent.
  • Marketing. Used to measure the effectiveness of our advertising and to
    show you relevant advertising on other platforms. These are set only with your
    explicit consent
    and are described in sections 9 and 10. You may withdraw your
    consent at any time with effect for the future.

7. Website analytics

We use Umami to understand how our website is used. We host Umami ourselves on our own
infrastructure; no data is passed to a third-party analytics provider.

Umami does not set cookies, does not use device fingerprinting, and does not create profiles
that follow you across websites. It records aggregated information such as the page visited,
the referring website, and approximate country. Because no information is stored on or read
from your device, this does not require your consent. The legal basis is our legitimate
interest in understanding and improving the use of our website.

8. Maps and spam protection

Google Maps. Our Stores and Contact pages use Google Maps to show where our
stores are. Google Maps is provided by Google Ireland Limited, Gordon House, Barrow Street,
Dublin 4, Ireland. When such a page loads, your IP address is transmitted to Google. This
serves our legitimate interest in presenting our locations and making them easy to find. Maps
is not loaded on other pages of this website.

hCaptcha. To protect our forms against misuse and spam we use hCaptcha,
a service of Intuition Machines, Inc., United States. hCaptcha analyses information including
your IP address, information about your browser and device, and your interaction with the page,
in order to distinguish human visitors from automated systems. This serves our legitimate
interest in protecting our website from misuse. Further information is available in
hCaptcha’s privacy policy.

9. Meta Pixel (Facebook and Instagram advertising)

What it is and why we use it. With your consent, we use the Meta Pixel, a
service of Meta Platforms Ireland Limited, Merrion Road, Dublin 4, Ireland (“Meta”). It allows
us to measure whether our advertising on Facebook and Instagram leads to meaningful actions on
our website — for example requesting directions to one of our stores, calling us, or contacting
us on WhatsApp — and to show advertising to people who have previously visited our website. Our
advertising is directed at people in Türkiye.

What is processed. When the pixel is active it processes your IP address,
information about your browser and device, the pages of our website you visit, and the actions
listed above. It stores and reads cookies on your device (including _fbp). If you
are logged into Facebook or Instagram, Meta can assign this information to your user
account.

Legal basis. Your explicit consent. The pixel is not loaded unless you
consent, and you may withdraw at any time with effect for the future.

Joint responsibility. For the collection of this data and its transmission
to Meta, we and Meta are jointly responsible. We have concluded Meta’s controller addendum,
under which Meta is responsible for data subject rights in respect of the data once
transmitted. The essence of that arrangement is available at
facebook.com/legal/controller_addendum.
For Meta’s subsequent processing, Meta alone is responsible.

Retention. We do not store this data ourselves; Meta’s own retention
periods apply.

More information.
Meta’s Privacy Policy ·
your Meta ad settings

10. Google Ads conversion measurement and remarketing

What it is and why we use it. With your consent, we use Google Ads, a
service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).
This lets us measure whether our advertisements lead to meaningful actions on our website — for
example requesting directions to one of our stores, calling us, or contacting us on WhatsApp —
and to show advertising to people who have previously visited our website. Our advertising is
directed at people in Türkiye.

What is processed. Cookies are stored on and read from your device
(including _gcl_au). Where you reach our website by clicking one of our
advertisements, a click identifier is processed. Google also processes your IP address,
information about your browser and device, and the actions listed above.

Legal basis. Your explicit consent. The tag is not loaded unless you
consent, and you may withdraw at any time with effect for the future.

Consent signalling. Where you do not consent, the Google Ads tag is not
loaded at all and no data is transmitted to Google.

Retention. We do not store this data ourselves; Google’s own retention
periods apply.

More information.
Google’s Privacy Policy ·
your Google ad settings

11. Social media

We maintain a presence on Instagram, Facebook, LinkedIn, Pinterest and Spotify, which lets
us communicate with our customers and share information about our pieces and our stores.

Our website links to those profiles. These are ordinary links: no social media
content is embedded in our pages, and no data is transmitted to those platforms simply because
you visit our website.
Data is transmitted only if you click a link and go to the
platform, or if you contact us there — in which case that platform’s own privacy policy applies
to what it does with your data, alongside ours.

12. International data transfers

Some of the services described above involve transferring personal data outside Türkiye.

Meta and Google. Data may be transferred to Meta Platforms, Inc. and Google
LLC in the United States. This transfer takes place on the basis of your explicit consent to
the marketing cookies described in sections 9 and 10. Both providers additionally maintain
their own safeguards for such transfers, including the EU–U.S. Data Privacy Framework and
Standard Contractual Clauses.

DHL. Where an item is shipped internationally, delivering it necessarily
involves transferring your delivery details to the destination country, as necessary for the
performance of your contract.

hCaptcha. The spam protection described in section 8 is provided by a
company established in the United States, and the information it analyses is processed there.
This is necessary to protect our forms from automated abuse.

Please note that authorities in third countries may be able to access such data, and that
enforcing your rights there may be more difficult than in Türkiye.

13. Your rights

Rights we grant voluntarily. As explained at the top of this policy, we
apply GDPR-level protections as a matter of choice. Accordingly, whoever and wherever you are,
you may ask us to give you access to your personal data, to correct it, to erase it, to
restrict how we process it, to provide it in a portable form, or to stop processing it. Where
our processing is based on your consent, you may withdraw that consent at any time with effect
for the future. We will honour these requests on the same terms as Articles 15 to 21 of the
GDPR, and we will not ask you to demonstrate that the GDPR applies to you.

Your rights under Turkish law — KVKK (Law No. 6698), Article 11. You have
the right to learn whether your personal data is processed; to request information about such
processing; to learn its purpose and whether it is used accordingly; to know the third parties
to whom it is transferred at home or abroad; to request correction of incomplete or inaccurate
data; to request erasure or destruction; to require that such correction or erasure be notified
to third parties to whom the data was transferred; to object to a result produced solely by
automated analysis; and to claim compensation for damage arising from unlawful processing. Our
supervisory authority is the Turkish Personal Data Protection Authority (Kişisel Verileri
Koruma Kurumu
), to which you may complain at any time.

How to exercise them. Write to us at
[email protected], or to Koç Deri ve Kuyumculuk
A.Ş., Molla Fenari, Tavuk Pazarı Sk. No: 27, 34126 Fatih/İstanbul, Türkiye. Requests under KVKK
must be made in accordance with the Communiqué on the Procedures and Principles of Application
to the Data Controller; we will respond within thirty days at the latest.

14. Updates to this policy

We review this policy annually or as needed. The latest version is always available on our
website.