Privacy Policy

Light34 Aydınlatma Sanayi ve Ticaret Limited Şirketi Privacy Policy

1. Purpose
Light34 Aydınlatma Sanayi ve Ticaret Limited Şirketi (hereinafter referred to as 'Light34', 'we' or 'us') wish to give all users the best possible experience of our digital solutions, and we therefore use data concerning customers and users combined with information collected from third-party solutions.

Light34 takes pride in taking care of all customer data and protecting the information collected. There are clearly defined procedures to ensure that all personal information is processed in accordance with current legislation, both internally at Light34and by our business partners Light34, is the data controller for all data.

This Privacy Policy specifies what data is collected via our digital solutions, the purposes for which such data is collected and used, how data is managed, and with whom data is shared. In addition, it also specifies what options you have with regards to the use or updating of your data.

When you visit Light34's websites, including light34.com, you accept the terms of this Privacy Policy, as well as the commercial terms and conditions (online), terms and conditions of sale and delivery, cookie policy and other documents specified in Light34's Privacy Policy. This Privacy Policy defines how we process all data attributable to natural persons which are collected via our digital solution. Light34's policies and practices regarding data and how we process them are described in further detail below.

Our Privacy Policy includes information about the collection and use of data that is collected via Light34's digital solutions, which include our website, webshop, newsletters, product registration, customer surveys, competitions, and other services where it is possible to register personal data.

You are always welcome to contact Light34 with any questions regarding our processing of personal data. You can find our contact details on the website and also at the end of this text.

2. Responsibility
Light34 is responsible for the purpose of and means for the processing of data, and we therefore reserve the right to protect your information in accordance with current legislation.

Light34 will obtain access to process the personal information and data described in this Privacy Policy. Light34 is the data controller and as the data controller we undertake to process all data collected in accordance with applicable Turkish legislation.

3. What data is collected
Here at Light34, we wish to protect the privacy of our customers and users no matter which digital solution they use, and so our collection and storage of data is therefore adapted based on the solution being used.

3.1 Automatically collected data
Light34's digital solutions are based on various different technologies in order to ensure ease of use and security. These technologies may collect data automatically in order to offer the best possible solution. This may be undertaken either directly by Light34 or by third parties on our behalf. Cookies and the analysis of clickstream data are examples of this.

3.1.1. Cookies
Cookies are small text files containing letters and numbers which are stored on your computer or other devices. Cookies are stored on your device whenever you visit a website that uses cookies and they can be used to track which pages you have visited, to help you to continue where you left off, or to remember your language settings or other preferences.

3.1.2. Clickstream data
All visits to any of our digital solutions entail data being sent from your browser to a server. Light34 can analyse this data in order to optimise its digital solutions. Data is collected via third parties on our behalf.

Data about your computer can be collected for system administration and internal marketing-related analyses. This data is statistical information concerning users' behaviour in the digital solutions.

Examples of the data that is collected and analysed:
• Date and time of visit
• The pages of the solution that are visited
• The IP address of the visitor
• Information about the browser and computer used (type, version, operating system, etc.)
• The URL from the point of referral (the page from which the visitor has come Light34's solution)

3.2 Information actively submitted by you
In addition to information that is collected automatically, we also process data that users have actively submitted to Light34.

Examples of data actively submitted by users include: personal and contact details such as email, telephone number, address, date of birth, etc. If you submit information on behalf of another person, it is your responsibility to ensure that you have the right to share such data with us.

This may also concern data that you share with us via Facebook, by participating in a competition, or in connection with registering to receive newsletters from Light34. Information may also be submitted to Light34 in connection with customer service or support enquiries.

4. Use and storage of the collected data
 
4.1 Purpose of collection
Some examples of how collected data may be used are given below:
• Adjustment of the content within digital solutions.
• Execution of orders in the online shop, including basket function, payment, checking of card data, etc.
• The opportunity to participate in customer surveys, competitions, lotteries, etc. via digital solutions.
• Archive of registered products and related personal data.
• Administration of memberships.
• Order processing and communication in connection with your order or other enquiries to Light34, including customer service.
• Confirmation of your identity when communicating with Light34.
• If we have your explicit consent, we may contact you using the contact details that you have submitted for marketing, sales, advertising and analytical purposes, either by post, digitally or via telephone/text message.
• We may target offers and campaigns for each customer on the basis of their behaviour history and demographic data, combined with third-party solutions and data.

4.2. Legal basis for processing
The legal bases used by Light34 to process your data for the purposes mentioned above are the following:

We process your data, first and foremost, in order to fulfil our agreements with you; this includes ensuring that we can make our deliveries to you as agreed, ensuring that our customer service team can help you and ensuring that we can comply with the warranty that we provide to you when you purchase and register our products.

Additionally, we will also process data for purposes that we consider to be in your interest, such as sending you marketing materials that are adapted to your preferences and therefore of the greatest possible interest to you.
For certain types of processing, such as the sending of newsletters, data processing will be based on consent that you have given.

4.3. Storage
The data is stored for the statutory period of time prescribed by current legislation and we delete data once it is no longer required. The period of time depends on the nature of the data and the reason that it is stored. Data used for electronic marketing purposes is retained for a maximum period of 12 months from the date on which it is last used, unless it is deleted before this point at your request.

5. Disclosure of information
 
5.1. In general
Light34 will only disclose customer information to a third party in accordance with the terms of this Privacy Policy.

We may disclose your information if we are subject to an obligation to forward or share data in order to comply with a legal obligation. Disclosure may also take place as instructed by a court of law or another authority, or to protect the trademarks, rights, property or security of Light34 Aydınlatma Sanayi ve Ticaret Limited Şirketi. This entails the exchange of information with other companies and organisations for the purpose of protection against fraud.

Light34 uses service providers and data processors which operate on our behalf. Such services may, for example, comprise server hosting and system maintenance, analysis, payment solutions, control of addresses and credit standing, email service, etc. These business partners may be given access to data to the extent necessary in order for them to provide their services and solutions. Such business partners will be contractually obliged to treat all data as strictly confidential and will thereby not have permission to use data for purposes other than those which are covered within their contractual relationship with Light34, and we check that our business partners comply with their obligations.

Please note that some of the before mentioned service providers are based outside of the EU, which means that in certain cases your data may be accessed from a country outside of the EU. Light34 has taken measures to ensure that such transfers are undertaken in accordance with the requirements for the legal transfer of personal data to third countries, including in particular the US-EN Privacy Shield and use of the European Commission's standard clauses.

When participating in dispute resolution procedures via the ODR platform http://ec.europa.eu/consumers/odr, Light34 may be required to disclose data and personal information to the European Commission, which is the operator of the platform.

5.2. Special information concerning Google Analytics
Light34 uses Google Analytics as a web analysis solution within our digital solutions. In connection with this, web analysis data is thereby sent from our digital solutions to be analysed in the service offered by Google. In this context, Google Analytics functions as the "data processor" and Light34  is the "data controller", and Light34 's data may only be disclosed by agreement or in order to comply with legal requirements.

You can read more about Google's privacy policy here:
https://policies.google.com/privacy

Google offers various solutions to protect the anonymity of your data and behaviour; see more here:

https://support.google.com/analytics/answer/181881?hl=en

5.3. Retargeting technologies
Our websites use retargeting technologies. This gives us the opportunity to advertise directly to our visitors on other websites. Based on the interest in visiting our websites, we believe that the display of personal interest-based advertising is more interesting for our customers than ads which do not bear any personal relation.

We also work together with partners which use tracking technologies in order to display digital ads on our behalf. These partners may collect information about your visits to our digital solutions and how you interact with our communications, including our advertisements.

Retargeting technologies analyse your cookies and display ads based on your previous online activity

6 Security
We have adopted internal information security rules which comprise of instructions and measures to protect your personal data from being destroyed, lost or changed, from unauthorised publication and from being accessed by or becoming known to unauthorised persons.

We have set out procedures for granting access rights to those of our employees who process sensitive personal data and data that reveals information concerning personal interests and habits. We control the actual access to such data via log-in functions and supervision. To avoid loss of data, we continuously backup our data sets. We also use encryption to protect the confidentiality and authenticity of your data. 

If you have chosen a password for one of Light34 's digital solutions, you are responsible for storing this password in a responsible way, and also for ensuring that your internet connection is secure whenever you use this password. Data transmission is never 100% secure via the Internet, but Light34 does its utmost to protect your personal data and to support secure digital communication.

7 Rights
 
7.1. You are in control
When you provide information to Light34, you do so on a voluntary basis. There are certain services and functions which can only be used if you choose to give us access to personal data; e.g. the completion of an order made via our webshop.

We offer our customers and users the opportunity to retain control over their data; among other things, this entails the option to delete accounts and subscriptions to digital services.

You are always welcome to use our online form or to send an email or letter if you would like information regarding what data we have registered. See our contact details at the end of this document. You are entitled to receive a copy of the personal data that we process on you, free of charge. Access to the disclosure of information may be limited, however, given the need to protect the privacy of others, as well as business secrets and intellectual property rights.

Please also note that reference is made from Light34's digital solutions to external media with their own privacy policies which lie beyond Light34's control. We recommend that you also keep yourself informed about their current policies.

7.2. Withdrawal of registration and objection
You have the right to object to our processing of your personal data.
If you receive emails with marketing content, you just need to click on the unsubscribe link in the email, after which you will no longer receive any further marketing material sent to the email address in question. If you would like to unsubscribe from all marketing material, whether digital or analogue, simply make a written request for this to Light34 with the heading "privacy – deletion". See our contact details at the end of this document.

If there is any doubt concerning your identity, then we may request further documentation, such as a copy of your passport, for example. Any costs associated with this are not covered by Light34. The use of personal data in connection with service and administrative enquiries may also be cancelled by contacting Light34 (see above), which will then delete the user manually.

7.3 Verification and updating of information
You also have the opportunity to have personal data stored by Light34 updated, supplemented, blocked or deleted, provided again that this can be undertaken in accordance with current legislation. If there are circumstances which prevent us from complying with your updating request, you will be informed of this within a reasonable period of time. See also our contact details at the end of this document.

8 Updating the policy
Light34 will comply at all times with applicable legislation and principles for privacy and data protection. We update this policy on an ongoing basis with regard to any changes in legislation, and to ensure that the policy reflects the current digital solutions that we offer to our customers.

Significant changes will be announced via our website and may also be notified by email.

9 Contact details
Write to: info@light34.com or to Light34, İkitelli O.S.B. Mutsan San. Sitesi M8 Block No:8 BAŞAKŞEHİR / İSTANBUL Please write "Privacy" in the subject heading or on the envelope.

You can also contact us using our online form, which you can find on our website. It can be located at the bottom of light34.com
 
Updated December 2019