PRIVACY AND COOKIE POLICY

As DEFNE RÜYA KOZMETİK SANAYİ VE TİCARET LİMİTED ŞİRKETİ (“Daffne”), we strive to protect the privacy of our members who use our site to ensure they benefit from our services securely and completely. Accordingly, this Daffne Privacy Policy (“Policy”) has been prepared to process our members' personal data in full compliance with the Turkish Personal Data Protection Law No. 6698 (“KVKK” or the “Law”) and to inform our users accordingly. The Daffne.com Cookie Policy is an integral part of this Policy.

The purpose of our PRIVACY AND COOKIE POLICY is to determine the terms and conditions regarding the use of personal data shared with Daffne by Platform members/visitors/users (collectively referred to as the “Data Subject”) or generated by Daffne during the Data Subject’s use of the www.daffne.com website, mobile site, and mobile application (collectively referred to as the “Platform”) operated by DEFNE RÜYA KOZMETİK SANAYİ VE TİCARET LİMİTED ŞİRKETİ.

What Personal Data is Processed?

The data processed by Daffne and considered personal data under the Law are listed below. Unless explicitly stated otherwise, the term “personal data” under the terms and conditions stated in our PRIVACY AND COOKIE POLICY will encompass the following information:

Identity Information
Contact Information
User Information
User Transaction Information
Transaction Security Information
Financial Information
Marketing Information
Request/Complaint Management Information

Data that has been irreversibly anonymized under Articles 3 and 7 of the Personal Data Protection Law will not be considered personal data according to the provisions of the mentioned law, and processing activities regarding such data will be carried out without being bound by the provisions of this Policy.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising.

Purposes of Processing Personal Data

Daffne may process personal data provided by the Data Subject for the purposes of creating a membership registration and account, maintaining related records, enabling the Data Subject to benefit from the services provided on the Platform, detecting system errors to monitor performance and improve the functioning of the Platform, providing maintenance, support, and backup services, carrying out the necessary work by business units to benefit relevant persons from the products and services offered by Daffne and executing business processes, planning and executing the activities necessary to customize and recommend these products and services according to the tastes, usage habits, and needs of the relevant persons, carrying out necessary work by relevant business units for the realization of commercial activities conducted by Daffne and executing connected business processes, ensuring the legal, technical, and commercial-occupational security of Daffne and persons in a business relationship with Daffne, and planning and executing Daffne's commercial and/or business strategies.

Personal Data to be Processed Based on Explicit Consent and Purposes of Processing

Within the scope of the Data Subject's explicit consent, Daffne may process data to track Data Subjects' movements on the Platform to enhance user experience, create statistics, segment users, conduct direct marketing and remarketing, create specific promotion and campaign suggestions for the Data Subject, and transmit them to the Data Subject. The data obtained in this context may be used in all kinds of advertising and material content and shared with the other parties stated below.

Data from Third-Party Marketplaces (Including Amazon)

In addition to our direct Platform operations, we collect and process data from third-party marketplaces, specifically Amazon, via the Selling Partner API (SP-API). We collect Amazon Information solely to fulfill customer orders and manage our internal supply chain.

Data Handling & Security: This data is stored securely in encrypted databases with strict Role-Based Access Controls (RBAC).
Data Sharing & Sale: We do not sell, rent, or lease any Amazon data to outside parties. We share this data exclusively with necessary operational partners (such as shipping carriers for generating shipping labels and authorized e-invoice integrators for legal tax invoicing) to complete fulfillment and comply with national tax laws. All shared data is restricted to the minimum necessity and handled per Amazon’s Data Protection Policy.
Data Retention & Disposal: All Personally Identifiable Information (PII) obtained from Amazon is permanently disposed of and deleted from our active systems within 30 days of order shipment. The only exception is PII embedded within legal tax invoices, which we are legally mandated to retain in secure, isolated archives to comply with national tax regulations.

Transfer of Personal Data

Daffne may transfer the personal data belonging to the Data Subject and the new data obtained using this personal data to third parties from whom Daffne receives services in order to realize the purposes determined by our PRIVACY AND COOKIE POLICY, limited to the provision and execution of these services. Daffne may share data with external service providers (including SMS and e-mailing senders), hosting service providers, law firms, research companies, and call centers to improve the Data Subject experience (including improvement and personalization), ensure Data Subject security, detect fraudulent or unauthorized use, conduct operational evaluation research, fix errors related to Platform services, and realize any of the purposes in this Privacy Policy.

Personal data may be shared with DEFNE RÜYA KOZMETİK SANAYİ VE TİCARET LİMİTED ŞİRKETİ officials, shareholders, business partners, suppliers, legally authorized public institutions and organizations, and legally authorized private institutions within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law, and may be transferred abroad limited to these purposes in accordance with the procedures and principles indicated in Article 9 of the Law and the decisions of the Personal Data Protection Board.

Method and Legal Reason for Collecting Personal Data

Personal data is collected electronically through the Platform. Personal data collected for the legal reasons stated above can be processed and transferred for the purposes specified in Articles 5 and 6 of Law No. 6698 and this Privacy Policy.

Rights of the Personal Data Subject

Under Article 11 of the Law, data subjects have the right to:

Learn whether their personal data is being processed,
Request information if their personal data has been processed,
Learn the purpose of processing personal data and whether they are used in accordance with their purpose,
Know the third parties to whom personal data is transferred domestically or abroad,
Request the correction of personal data if it is incomplete or improperly processed and request that the transaction carried out in this context be notified to third parties to whom the personal data has been transferred,
Request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear, although it has been processed in accordance with the provisions of the Law and other relevant laws, and request that the transaction carried out in this context be notified to third parties to whom the personal data has been transferred,
Object to the occurrence of a result against the person by analyzing the processed data exclusively through automated systems,
Demand the compensation of the damage in case of damage due to the unlawful processing of personal data.

Requests regarding the exercise of these rights can be submitted by personal data subjects through the methods specified in the Policy on the Processing and Protection of Personal Data prepared by Daffne within the scope of Law No. 6698, available at www.daffne.com. Daffne will conclude these requests within thirty days. Daffne reserves the right to charge a fee based on the fee schedule (if any) determined by the Personal Data Protection Board regarding the requests.

COOKIE POLICY

As DEFNE RÜYA KOZMETİK SANAYİ VE TİCARET LİMİTED ŞİRKETİ (“Daffne”), we strive to protect the privacy of the people who use our site to ensure that our users benefit from our services and products securely and completely. As with most websites, Daffne.com (the “Site”), mobile site, and mobile application (collectively referred to as the “Platform”) use Cookies to show personalized content and advertisements to visitors and customers, perform analytical activities within the site, and track visitor usage habits. The Daffne Cookie Policy is an integral part of the Daffne.com Privacy Policy. Daffne has prepared this Cookie Policy (“Policy”) to explain the Cookies used on the Site and how users can manage and change their preferences in this regard. For more detailed information on the processing of your personal data by Daffne, we recommend you review the Daffne.com Privacy Policy.

What is a Cookie?

Cookies are small text files that are stored on your device or network server via browsers by the websites you visit. Cookies are created by servers associated with the website you visit. Thus, when the visitor visits the same site, the server can understand this. Cookies do not contain personal data such as name, gender, or address regarding the visitors. For more detailed information on cookies, you can visit www.aboutcookies.org and www.allaboutcookies.org.

Which Cookies Are Used?

Cookies can be categorized in terms of their owners, lifespans, and intended uses:

Depending on the party placing the cookie, Platform cookies and third-party Cookies are used. Platform cookies are created by Daffne, while third-party cookies are managed by different companies that cooperate with Daffne.
Depending on the time it is active, session cookies and persistent cookies are used. Session cookies are deleted when the visitor leaves the Platform, while persistent cookies can remain on the visitors' devices for various periods depending on the usage area.
Depending on the purpose of use, technical cookies, verification cookies, targeting/advertising cookies, personalization cookies, and analytical cookies are used on the Platform.

To personalize and improve the content to be presented to you, including advertising, during your visit to our Website, the following Cookies from third-party websites may be stored on your device:

Social Network Content: We may publish content from social networks on our support pages. Therefore, by referring to this content on our support pages, a Cookie from the relevant social network may be stored on your device. We recommend you read the cookie policies of these social networks for more detailed information.
Flash Cookies: These are files stored by the Flash software. This tool is mostly installed as an extension of internet browsers to display dynamic objects such as moving graphics or video directories. Therefore, Flash Cookies may be installed due to the use of this application. For more information, we recommend you read the cookie policy on www.adobe.com.

Why Are Cookies Used?

On the Platform, Cookies are used for the following purposes:

To perform the basic functions necessary for the Platform to work. For example, the items in the Daffne members' product cart do not disappear during their visits. Logged-in members do not need to re-enter passwords when visiting different pages on the Platform.
To analyze the Platform and improve its performance. For example, integrating different servers on which the Platform works, determining the number of visitors to the Platform and making performance settings accordingly, or making it easier for visitors to find what they are looking for.
To increase the functionality of the Platform and provide ease of use. For example, sharing to third-party social media channels through the Platform, remembering the username information or search queries of the visitor who visits the Platform in a subsequent visit.
To perform personalization, targeting, and advertising activities. For example, displaying advertisements linked to visitors' interests based on the pages and products they view.

How Can You Manage Your Cookie Preferences?

Daffne attaches great importance to users being able to exercise their preferences over their personal data. However, preference management is not possible for some Cookies that are mandatory for the Site to function. We also would like to inform you that if some Cookies are turned off, various functions and features of the Site may not work.

Information on how preferences regarding the Cookies used on the Platform can be managed is as follows:

Visitors have the opportunity to customize their preferences regarding cookies by changing the browser settings in which they view the Platform. If the browser in use offers this possibility, it is possible to change the preferences regarding Cookies via the browser settings. Thus, although it may differ depending on the possibilities offered by the browser, data subjects have the opportunity to prevent the use of cookies, prefer to receive a warning before a cookie is used, or simply disable or delete some Cookies. Although preferences in this regard vary according to the browser used, general explanations can be reached at https://www.aboutcookies.org/. Preferences regarding cookies may need to be made separately for each device the visitor accesses the Platform.
Click to turn off Cookies managed by Google Analytics.
Click to manage the personalized advertising experience provided by Google.
Preferences regarding cookies used by many companies for their advertising activities can be managed via Your Online Choices.
To manage Cookies on mobile devices, the settings menu of the mobile device can be used.

What Are Your Rights?

Pursuant to Article 11 of the Personal Data Protection Law No. 6698, visitors can apply to Daffne to:

Learn whether personal data is processed,
Request information if personal data has been processed,
Learn the purpose of processing personal data and whether they are used appropriately,
Know the third parties to whom personal data is transferred domestically or abroad,
Request correction if personal data is processed incompletely or incorrectly and request notification of the transaction made in this context to third parties to whom personal data has been transferred,
Request deletion or destruction of personal data if the reasons requiring processing disappear, although it has been processed in accordance with the Law and other relevant laws, and request notification of the transaction made in this context to third parties to whom personal data has been transferred,
Object to a result against the person arising from analyzing the processed data exclusively through automated systems,
Demand compensation for damages in case of damage due to unlawful processing of personal data.

These rights will be evaluated and finalized within 30 (thirty) days at the latest when submitted by personal data subjects through the methods specified in the Policy on the Processing and Protection of Personal Data prepared by Daffne within the scope of Law No. 6698. Although it is essential that no fee is charged for requests, Daffne reserves the right to charge a fee based on the fee schedule determined by the Personal Data Protection Board.

Changes to Consent and Privacy Policy

With the Privacy Policy (“Policy”), Daffne aimed to provide its users with a detailed explanation about the scope and purposes of Cookie usage and to inform its users about Cookie preferences. In this regard, if the Cookie information warning on the Platform is closed and the Site is continued to be used, it is accepted that consent has been given for Cookie usage. Users always reserve the right to change their Cookie preferences. Daffne may change the provisions of the Policy at any time. The updated Policy becomes effective on the date it is published on the Platform.