4. HOW WE USE YOUR PERSONAL DATA

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We may process your personal data for the following purposes:

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4.1 Processing and Fulfilling Orders

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To:

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• process purchases;

• confirm orders;

• arrange production where applicable;

• arrange delivery;

• process payments;

• provide order updates;

• manage returns and exchanges; and

• provide customer support.

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4.2 Customer Accounts

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To:

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• create and manage customer accounts;

• maintain order history;

• manage saved information;

• administer Alexander Balance or other account features; and

• provide account-related services.

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4.3 Customer Service

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To:

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• respond to enquiries;

• investigate complaints;

• process returns and exchanges;

• assess product issues;

• communicate with customers regarding orders; and

• provide after-sales support.

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4.4 Custom and Made-to-Measure Products

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To:

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• assess custom-product requests;

• communicate with you regarding specifications;

• confirm material availability;

• determine pricing;

• produce the requested product; and

• fulfil the order.

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4.5 Website Operation and Security

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To:

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• operate and maintain our website;

• prevent fraud, abuse and unauthorised activity;

• maintain website security;

• identify technical problems;

• improve website performance; and

• protect our systems, business and customers.

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4.6 Legal and Regulatory Compliance

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To:

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• comply with applicable laws and regulations;

• maintain legally required records;

• respond to lawful requests from authorities;

• establish, exercise or defend legal claims; and

• protect our legal rights and legitimate business interests.

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4.7 Marketing and Communications

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Where permitted by applicable law and, where required, with your consent, we may use your contact information to send:

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• product announcements;

• new collection information;

• promotional communications;

• brand news; and

• other marketing communications.

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You may unsubscribe from marketing communications at any time using the unsubscribe mechanism provided in the relevant communication or by contacting us.

 

5. LEGAL BASES FOR PROCESSING

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Depending on the circumstances and the applicable law, Alexander may process personal data on the following legal bases:

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• Performance of a contract — for processing and fulfilling orders, arranging delivery, processing returns and exchanges, providing customer service, and otherwise performing our contractual obligations.

• Compliance with legal obligations — where processing is necessary to comply with applicable tax, accounting, consumer-protection, customs, regulatory or other legal requirements.

• Legitimate interests — where processing is necessary for purposes such as operating and securing our website, preventing fraud or misuse, maintaining business records, improving our services, protecting our legal rights, and establishing, exercising or defending legal claims, provided that such interests are not overridden by applicable data-protection rights.

• Consent — where we are legally required to obtain your consent, including for certain marketing communications, cookies or other optional processing activities.

• Other lawful grounds — where another legal basis is available under applicable legislation.

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Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

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Alexander will process personal data only where a lawful basis for doing so exists under KVKK and, where applicable, GDPR, UK GDPR or other applicable data-protection legislation.

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6. WHO WE MAY SHARE YOUR PERSONAL DATA WITH

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Alexander may share personal data with third parties where necessary to operate our business, provide our services, fulfil orders, process transactions, comply with legal obligations, or protect our legitimate interests.

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Depending on the circumstances, personal data may be shared with the following categories of recipients:

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Website and Technology Providers

We may share or make personal data available to Wix, as the platform on which our website is built and operated, and to relevant Wix Apps and integrated service providers where necessary to provide website functionality, operate our systems, maintain security, or provide other services available through the website.

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Payment Service Providers

We may share information necessary to process and confirm payments with iyzico or another authorised payment service provider. The payment provider may independently process payment information in accordance with its own privacy policy and applicable legal requirements.

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Delivery and Logistics Providers

We may share information necessary to fulfil and deliver an order with courier companies, cargo companies, postal operators and other logistics providers. This may include the customer's name, telephone number, delivery address, order information and other information reasonably necessary for delivery.

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Customs and Import-related Parties

For international shipments, relevant information may be shared with customs authorities, customs brokers, import agents and other parties involved in customs clearance where necessary to complete the shipment or comply with applicable law.

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Professional Advisers and Service Providers

Where reasonably necessary, personal data may be shared with professional advisers and service providers such as accountants, lawyers, auditors, consultants and other providers assisting Alexander with its business operations.

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Public Authorities and Legal Recipients

Alexander may disclose personal data to courts, regulators, law-enforcement authorities, tax authorities, customs authorities or other public bodies where required or authorised by applicable law, or where necessary to establish, exercise or defend legal claims.

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Security, Fraud Prevention and Technical Service Providers

Where Alexander uses third-party services for website security, fraud prevention, technical support, analytics or similar purposes, relevant personal data may be shared with or processed by those providers to the extent necessary for the relevant service and permitted by applicable law.

 

Alexander does not sell, rent or otherwise commercially trade customers' personal data to third parties.

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Third parties that process personal data on their own behalf may have their own privacy policies and legal obligations. Where applicable, their processing of personal data is governed by their respective privacy policies and contractual arrangements with Alexander.

 

7. INTERNATIONAL DATA TRANSFERS

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Because Alexander is based in Türkiye and provides services to customers internationally, personal data may be transferred to or processed in countries outside Türkiye when necessary to operate our website, process orders, provide services, process payments, arrange delivery, provide technical services, or otherwise conduct our business.

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Such transfers may involve Wix, Wix Apps, iyzico, delivery and logistics providers, and other service providers used by Alexander.

Where personal data is transferred outside Türkiye, Alexander will carry out the transfer in accordance with KVKK and other applicable data-protection legislation and will use an applicable lawful transfer mechanism where required.

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Depending on the circumstances, this may include:

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• a country, sector or international organisation benefiting from an applicable adequacy decision;

• an appropriate safeguard recognised under applicable law, including an applicable standard contractual arrangement;

• another lawful transfer mechanism available under applicable law; or

• where permitted by law, a specific exception applicable to the relevant transfer.

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For transfers subject to GDPR or UK GDPR, where applicable, Alexander will use an appropriate lawful transfer mechanism, such as an applicable adequacy decision or appropriate contractual safeguards.

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Alexander may therefore process personal data in jurisdictions other than the country in which the customer resides. The applicable protections and transfer mechanisms will depend on the specific service provider, destination and legal framework governing the transfer.

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Wix, iyzico and other third-party service providers may independently process or store personal data in countries determined by their respective operations. Their own privacy policies provide further information regarding their international data processing and transfers.

 

8. DATA RETENTION

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Alexander retains personal data only for as long as reasonably necessary for the purposes for which it was collected, or for the period required by applicable law.

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The retention period may therefore vary depending on the type of personal data and the purpose for which it is processed. This may include the time necessary to:

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• fulfil and manage orders;

• provide customer service and after-sales support;

• process returns and exchanges;

• maintain accounting, tax, commercial and transaction records;

• comply with legal and regulatory obligations;

• resolve disputes and complaints; and

• establish, exercise or defend legal claims.

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Where applicable law requires Alexander to retain particular records for a specific period, those records will be retained for the legally required period.

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When personal data is no longer required for the purpose for which it was collected and there is no legal obligation or other lawful basis requiring its continued retention, Alexander will delete, destroy or anonymise the relevant personal data in accordance with applicable law and its internal data-retention and disposal procedures.

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Different categories of personal data may therefore be retained for different periods.

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Personal data processed or stored by Wix, Wix Apps, iyzico and other third-party service providers may be retained by those providers in accordance with their own applicable privacy policies, contractual obligations and legal requirements. Alexander does not determine the independent retention periods applied by such providers.

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9. DATA SECURITY

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Alexander takes reasonable technical and organisational measures designed to protect personal data against:

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• unauthorised access;

• unlawful processing;

• accidental loss;

• destruction;

• alteration; and

• unauthorised disclosure.

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However, no website, electronic transmission or storage system can be guaranteed to be completely secure.

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Where appropriate, access to personal data is restricted to persons and service providers who require the information for legitimate business purposes.

 

10. COOKIES AND SIMILAR TECHNOLOGIES

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Alexander uses cookies and similar technologies on its Website to support website functionality, security, preferences, analytics, performance, and, where applicable, marketing activities.

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Cookies may be placed by Alexander, Wix, Wix Apps, or other third-party services integrated with the Website. The specific cookies and similar technologies used may vary depending on the Website's functionality, applications, integrations and services in use at a particular time.

Cookies and similar technologies may be used for the following purposes:

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• Strictly necessary cookies — to enable essential Website functions, security, account functionality, shopping-cart and checkout functions, and other services requested by the visitor.

• Functional and preference cookies — to remember settings and preferences and provide additional Website functionality.

• Analytics and performance cookies — to understand how visitors use the Website and to measure and improve Website performance.

• Marketing and advertising technologies — where applicable, to measure marketing activity, understand interactions with advertising or marketing communications, or provide more relevant content or advertising.

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Where applicable law requires consent for non-essential cookies or similar technologies, Alexander will obtain the required consent before using them. In particular, the Turkish Personal Data Protection Board has stated that, where no other lawful processing condition applies, explicit consent should be obtained on an opt-in basis for non-essential functionality, analytics, performance, advertising and marketing cookies.

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Strictly necessary cookies may be used without explicit consent where permitted by applicable law and where an appropriate legal basis for the underlying personal-data processing exists.

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Where a cookie-consent mechanism is provided, visitors may be able to accept or reject non-essential cookie categories and change their preferences. Wix currently provides cookie-consent functionality that can allow website owners to manage consent for non-essential cookies and maintain records of visitors' cookie choices.

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Alexander's use of cookies and similar technologies is described in greater detail in our Cookie Policy, which explains the categories of cookies used, their purposes, the role of third-party providers, and how visitors can manage their preferences.

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Cookie Policy: [INSERT LINK TO COOKIE POLICY]

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Please note that cookies and similar technologies placed or controlled directly by third-party providers may also be subject to those providers' own privacy policies and terms. Alexander does not independently determine the processing practices of third parties acting in their own capacity.

 

11. YOUR RIGHTS UNDER KVKK

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Subject to the conditions and limitations provided by applicable law, individuals whose personal data is processed by Alexander may have the right to:

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• learn whether their personal data is being processed;

• request information regarding the processing of their personal data;

• learn the purpose of processing and whether the data is being used in accordance with that purpose;

• know the third parties to whom personal data has been transferred, within or outside Türkiye;

• request correction of incomplete or inaccurate personal data;

• request deletion or destruction of personal data where the applicable legal conditions are satisfied;

• request notification of correction, deletion or destruction to relevant third parties where required by law;

• object to certain consequences arising from the processing of personal data through automated systems, where applicable; and

• request compensation for damages arising from unlawful processing, where applicable.

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These rights are subject to the conditions and exceptions set out in KVKK and other applicable legislation.

 

12. YOUR RIGHTS UNDER GDPR AND UK GDPR

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Where GDPR or UK GDPR applies to the processing of your personal data, you may, subject to applicable conditions and exceptions, have rights including:

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• the right to be informed about the processing of your personal data;

• the right to access your personal data;

• the right to request correction of inaccurate or incomplete personal data;

• the right to request erasure of personal data;

• the right to request restriction of processing;

• the right to data portability;

• the right to object to certain processing, including direct marketing;

• the right to withdraw consent where processing is based on consent; and

• rights relating to certain automated decision-making and profiling, where applicable.

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The availability of these rights depends on the applicable law and the circumstances of the processing.

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Privacy information should be provided clearly and at the time personal data is collected, and applicable GDPR/UK GDPR frameworks also require information concerning purposes, legal bases, recipients, retention and international transfers.

 

13. MARKETING COMMUNICATIONS

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Alexander may send customers and other individuals marketing communications about Alexander products, collections, launches, promotions, special offers, events and other brand-related information where we have a lawful basis to do so and, where required, have obtained the necessary consent.

Marketing communications may be sent by email, SMS, or other electronic communication channels for which the recipient has provided the required permission.

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Marketing consent is voluntary and is not a condition of purchasing products, creating an account, or using the Alexander website. Where consent is required, it will be requested separately from acceptance of the Terms & Conditions, Privacy Policy, or other documents.

You may withdraw your marketing consent or unsubscribe from marketing communications at any time. Each marketing email will generally include an unsubscribe or similar mechanism where applicable. You may also contact us at brand@alexander.shop to request that marketing communications be stopped.

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Withdrawing marketing consent will not affect the lawfulness of processing carried out before the withdrawal.

Please note that transactional or service-related communications are not marketing communications. We may continue to send communications that are necessary to process or manage your order, account, payment, delivery, return, exchange, customer-service request, security, or other contractual or legal matter.

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Where applicable law permits certain communications without separate marketing consent, Alexander may send those communications in accordance with the applicable legal requirements.

Alexander will maintain appropriate records of marketing preferences and consent where required to demonstrate compliance with applicable data-protection and electronic-commerce laws.

 

14. CHILDREN'S DATA

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Our website and services are not intentionally directed toward children who are not legally permitted to enter into purchases or provide personal data under applicable law.

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We do not knowingly collect personal data from children for marketing purposes.

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If you believe that a child has provided personal data to Alexander without appropriate authorisation, please contact us at brand@alexander.shop.

 

15. THIRD-PARTY WEBSITES AND SERVICES

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Our website may contain links to third-party websites, social-media platforms, payment providers or other external services.

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Alexander is not responsible for the privacy practices, security or content of third-party websites or services.

 

We recommend reviewing the privacy policies of those third parties before providing them with personal data.

 

16. DATA BREACHES AND SECURITY INCIDENTS

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If Alexander becomes aware of a personal-data breach, we will assess the incident and take the measures required under applicable law.

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Where notification to a supervisory authority or affected individuals is legally required, Alexander will make such notifications within the applicable legal timeframe.

 

17. HOW TO EXERCISE YOUR RIGHTS

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If you wish to exercise any of your rights described in this Privacy Policy, you may contact Alexander using the contact details provided below.

For requests relating to your personal data processed by Alexander, please contact:

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KRAL AYAKKABI DERİ VE TEKSTİL SAN. TİC. A.Ş.
Trading as Alexander Leather & Fur
Gökalp Mah. 34. Sokak No:30
34020 Zeytinburnu / İstanbul
Türkiye

Email: brand@alexander.shop
Telephone: +90 532 260 41 51

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To help us process your request, we may ask you to provide information reasonably necessary to verify your identity and locate the relevant personal data or records.

 

Your request should clearly state the right you wish to exercise and provide sufficient information for us to understand and assess your request. Where required under applicable law, requests may need to be submitted using a legally recognized application method.

 

Under KVKK, data subjects may submit requests concerning their rights through the methods prescribed by applicable legislation, including in writing, through registered electronic mail (KEP), secure electronic signature, mobile signature, an email address previously registered in the data controller's system, or another method permitted by the relevant rules.

 

Alexander will review and respond to valid requests as soon as reasonably practicable and, where KVKK applies, no later than thirty (30) days, subject to applicable legal requirements. Requests are generally handled free of charge, although a fee may be permitted where the applicable legislation allows one due to additional costs.

 

Where Alexander is unable to comply with a request, we will provide the applicable explanation or legal grounds for refusing the request, where required.

 

If your request concerns personal data processed directly by Wix, Wix Apps, iyzico, or another independent third-party service provider, you may also need to contact that provider directly. Alexander will assist where appropriate, but cannot exercise rights on behalf of an independent data controller where the relevant data processing is controlled by that provider.

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Complaints under KVKK

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If a request made to Alexander is refused, the response is considered insufficient, or Alexander does not respond within the applicable period, the data subject may have the right to lodge a complaint with the Turkish Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu — KVKK) in accordance with Article 14 of Law No. 6698.

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Under KVKK, where the data subject receives a response, a complaint may generally be made to the Board within thirty (30) days from learning of the response and, in any event, within sixty (60) days from the date of the original application. Where no response is received, the sixty-day period applies from the date of the application.

 

18. COMPLAINTS AND SUPERVISORY AUTHORITIES

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If you have concerns about how Alexander processes your personal data, we encourage you to contact us first so that we can investigate and address the matter.

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You may also have the right to lodge a complaint with the competent data-protection supervisory authority in the country or jurisdiction applicable to you.

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For Türkiye, the relevant supervisory authority is the:

Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu – KVKK)

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The applicable complaint procedures and requirements are determined by Turkish law.

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Where GDPR or UK GDPR applies, you may also have the right to complain to the relevant data-protection supervisory authority in your jurisdiction.

 

19. CHANGES TO THIS PRIVACY POLICY

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Alexander may update this Privacy Policy from time to time to reflect:

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• changes in our business or services;

• changes to the technologies we use;

• changes in applicable legislation;

• regulatory guidance; or

• changes to our data-processing practices.

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The updated version will be published on this page with its revised “Last Updated” date.

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Where required by applicable law, we will provide additional notice or obtain consent before introducing materially different processing activities.

 

20. CONTACT US

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If you have any questions regarding this Privacy Policy, our processing of personal data, or your privacy rights, please contact:

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KRAL AYAKKABI DERİ TEKSTİL SAN. VE TİC. A.Ş.
Alexander

Gökalp Mah. 34. Sokak No:30
34020 Zeytinburnu, İstanbul
Türkiye

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Email: brand@alexander.shop
Telephone: +90 532 260 41 51
MERSIS No.: 0589048229500013
Tax No.: 5890482295

Tax Office: Zeytinburnu