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PRIVACY POLICY

Effective Date: 01/06/2024

Privacy is important to Sacre Global. The following describes the information we collect and the ways we use that information. By using www.sacreglobal.com and/or www.sacreglobal.com.eu (the “Websites”) or any mobile applications we may develop in the future (each, an “App”) and engaging with our services (collectively, the “Services”), you are consenting to the collection, use, sharing, and storage of your personal information, as described below. This Privacy Policy supplements and is incorporated into our Terms of Service which, together with this Privacy Policy, govern your use of the Services. We have endeavored to make this Privacy Policy as clear as possible. If, however, you have any questions, comments or concerns about this Privacy Policy, please send us an email at info@sacreglobal.com

The terms “Sacre Global” 'Sacre' or “us” or “we” or “our” refer to SELİN İNŞ. TİC. LTD. ŞTİ. , the owner of the Services. The terms “you” or “your” refer to the user or viewer of the Services.

Information We Collect
We collect information from those who visit and interact with our Services. This information may include the following:

full name, email address, mailing address, and phone number;
location and demographic data;
order and payment information provided by you or by third party processors, such as Shopify; and
comments, requests, and other information you may offer.

We may also collect other non-identifiable information related to your access to our Services, including, but not limited to, device and browser information, your IP address, Services visits, page response times, download errors, length of visits to certain pages, and page interaction information.

We collect the above information directly from you when you provide it to us, automatically as you navigate the Services, and from third-party service providers.

How We Use This Information
We use this information to facilitate the requested services, such as fulfilling orders and requests made through the Websites and App. We also use this information to track user behavior so that we can better market our services to you. We also use the above information to improve our Services.

Sharing Your Information
We do not ever sell your personal information for commercial purposes. We may share your information to facilitate the Services you obtain from us and to monitor or improve our Services. We may also share information with third parties in limited circumstances, such as complying with legal processes, cooperating with law enforcement, preventing fraud or imminent harm, ensuring the security of our network and services, when we believe your actions violate our Terms of Service, or in the event we are transferred or sold to another entity as a result of a corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

Retention of Information
We will retain personal information about you no longer than necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required and authorized by applicable law.

Third Parties
Your information may be held by third parties or we may link to other sites or applications not affiliated, owned, or controlled by us. Further, we may use products and services of third parties, for which the disclosure of your information is necessary, to help us better provide our Services to you (such as Google Drive, Squarespace, and Paypal for payments). We expressly disclaim any and all liability for the actions of third parties. The privacy practices of any third parties are outside the scope of this Privacy Policy and their use or disclosure of your information (including your personal information) will be governed by their own privacy practices or policies. We encourage you to review the privacy practices or policies of those third parties.

Your Rights
If you would like to access, modify, or delete your personal information, you may submit a request to info@sacreglobal.com. For more information or to see if these rights apply to you, please contact us. We will promptly review all such requests in accordance with applicable laws.

California Privacy Notice
This Privacy Notice for California residents supplements the information contained in this Privacy Policy. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).

The CCPA defines “personal information” as, “categories of information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly to a particular individual or household.” Personal information does not include publicly available information from government records or de-identified or aggregated consumer information. Further, the following information is excluded from the CCPA’s scope and is not classified as personal information under the CCPA:

health or medical information covered by the Health Insurance Portability and Accountability Act of 1996, Health Information Technology for Economic and Clinical Health Act, the California Confidentiality of Medical Information Act, or clinical trial data; and
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

NOTICE AT COLLECTION: The following lists describe the personal information we collect and the purposes for which we will use it.

Purposes for which we will use personal information

To enable you to make purchases and facilitate requested Services;
To provide you with services of the Website and customer service;
To improve our services or ensure the security of our network and services; and
For marketing purposes.

We collect, receive, and/or maintain the following categories of personal information:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Inferences drawn from other personal information, such as a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

We may use the above information for the business purposes outlined above, and we obtain the above information either (1) directly from you; (2) automatically as you navigate our services and products; and (3) from third parties that interact with us in connection with the services we perform.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category	Examples	Disclosed	Business Purpose
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES	To facilitate your purchases and to track your order information We process personal data for these purposes because it is necessary to perform a contract with you and for our legitimate interest in managing and operating our business.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES	To facilitate your purchases and to track your order information We process personal data for these purposes because it is necessary to perform a contract with you and for our legitimate interest in managing and operating our business.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES	To facilitate your purchases and to track your order information We process personal data for these purposes because it is necessary to perform a contract with you and for our legitimate interest in managing and operating our business.
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES	We track user behavior to improve our Services and help us improve the quality of the online experience. We process this information because it is necessary for our legitimate interests in operating and improving our Services.
G. Geolocation data.	Physical location or movements.	YES	To roughly estimate geolocations from where our users access the Services and to personalize content. We process this information because it is necessary for our legitimate interests in operating and improving our Services.
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Inferences drawn from other personal information, such as a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES	To understand customer behavior or preferences. We process this information because it is necessary for our legitimate interests in operating and improving our Services.

We disclose the above information for a business purpose to the following categories of third parties:

Our affiliates
Service providers
Other third parties identified in this Privacy Policy

In the preceding twelve (12) months, we have not sold any personal information.

Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

We do not provide these access and data portability rights for B2B personal information.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by mailing or emailing us your request pursuant to the contact information contained in the Privacy Policy.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information, at our discretion, that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by mailing or emailing us your request pursuant to the contact information in Section 9.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by mailing or emailing us your request pursuant to the contact information contained in this Privacy Policy.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please submit a request to us by mailing or emailing us your request pursuant to the contact information contained in this Privacy Policy.

Rights for Persons Covered by GDPR
If you are “data subject” for whom the processing of personal information is subject to REGULATION (EU) 2016/679 (GDPR) or the U.K. General Data Protection Regulation (“UK GDPR”) (“Covered Person”), the rights described in sections (A) through (G) apply to you.

Right of access, rectification, erasure and restriction of processing: you may obtain access to your personal information stored by us by contacting us. If we process or use your personal information, we shall endeavor to ensure, by implementing suitable measures, that your personal information is accurate and up to date for the purposes for which they were collected. If your personal information is inaccurate or incomplete, you may obtain the rectification of such personal information by contacting us. You may obtain the erasure or restriction of processing of your personal information in situations where no legitimate business purpose exists or the further storage is unnecessary under statutory storage obligations.
Right to data portability: you may receive the personal information about you that you have provided to us, in a structured, commonly used and machine-readable format or transmit this information to another controller. To exercise this right, contact us.
Right to object: you may object, on grounds relating to your particular situation, to the processing of your personal information. To exercise this right, you must contact us as provided herein. To the extent your personal information is processed for reasons other than direct marketing, you understand and agree that we have compelling legitimate reasons for information processing, such as providing access to our Services. You may use ad-blocking software to limit information capture and usage. You may also contact us with questions about this policy or to make a removal request. Making a request does not guarantee that the request will be honored.
Right to withdraw your consent: If you have given your consent to the collection or processing of your personal information, you may withdraw your consent without affecting the lawfulness of processing based on consent before its withdrawal by contacting us in writing.
Right to lodge a complaint: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority in the Member State of your residence, place of work or place of alleged infringement if you consider the processing of your personal data is infringing on GDPR or UK GDPR.
We currently store your personal information in the United States, but your personal information may be transferred, stored, or processed in a location outside of the United States.
If you make a request under sections (A) – (E) above, requests can be emailed directly to info@sacreglobal.com. Please try to provide us with as much detail as possible as to what you are seeking. The GDPR and UK GDPR allow us one (1) calendar month to respond to requests from the date we receive your request.
The legal basis for processing your personal information is:
1. You have given us consent by agreeing to abide by our Privacy Policy and Terms of Service and continuing to access the Services; and
2. Processing is necessary in order for us to comply with legal obligations.

Children’s Online Privacy Protection Act
The Services are intended for general audiences and is not directed to children under 13 years old. We do not target this Services to children under 13, and we do not intentionally collect any information from users under 13. If you become aware that your child has used the Services, and we may have personal information about a user under 13, please contact us at info@sacreglobal.com so we may delete the information.

Cookies
Cookies are small bits of electronic information that a website or application sends to your browser and are stored on your hard drive. We use cookies to identify users, track your behavior on the Websites and App, keep the Services secure, and improve the Services’ performance. Some cookies are necessary in order to use the Services, and these cannot be disabled. Other cookies are not required to browse our Services and may be disabled or deleted, but this may prevent you from properly using the Services. Most browsers allow you to adjust your cookie settings, which can be done through your browser’s settings.

Third-party services, such as İKAS, may employ cookies on the Services in order to better perform their services. İKAS's cookie policy can be found on their website.. We may receive cookie information from third-party websites like İKAS. We have no control over third-party cookies, and therefore, disclaim any and all liability related to third-party cookies.

Changes and Updates to Privacy Policy
This Privacy Policy may be revised periodically, and this will be reflected by the date above. Please revisit this page to stay aware of any changes. Your continued use of the Services constitutes your agreement to this Privacy Policy and any future revisions.

Contact Information
If you have any questions or concerns about this Privacy Policy, please contact us by mail or email using the following information:

SACRE GLOBAL

info@sacreglobal.com