MAVI PRIVACY POLICY 

Mavi Giyim Sanayi ve Ticaret A.Ş., a joint-stock company incorporated under the laws of the Republic of Türkiye (referred to herein as “Mavi”, “we”, “our”, or “us”), is committed to protecting your privacy online and adhering to all applicable laws and regulations related to data privacy and protection.

 

This Privacy Policy is designed to help you, as a data subject, understand how we use your Personal Data when you visit the Mavi website.

For the purposes of this Privacy Policy, “Website” refers to the mena.mavi.com website, and “you” and “your” refers to a specific individual accessing the Website.

1.         Purpose of this Privacy Policy

• Our Privacy Policy applies to the collection, processing, and use of your Personal Data when you use our Website.
• For the purposes of this Privacy Policy, “Personal Data” is information that relates to you, or that allows us to identify you. Personal Data includes data, regardless of its source or form, that may lead to identifying you as an individual specifically, or that may, directly or indirectly, make it possible to identify you as an individual, including name, personal identification number, addresses, contact numbers, license numbers, records, personal assets, bank and credit card numbers, photos and videos, and any other data of personal nature. This can also include information such as our analysis of your use of our Website.
• We will process your Personal Data in our capacity as a data controller.

 

Collecting, Purposes and Legal Basis Processing of Personal Data

 

• We only collect Personal Data about you in connection with the operation of our Website. We will hold information about you if you visit our Website in accordance with applicable data protection laws and regulations.

 

• A non-exhaustive, indicative list of the types of information we process about you and the purposes for which we process the information includes, inter alia:

 

Type of Personal Data	Purposes	Legal Basis
Identity (name,surname) Contact (e-mail address, address)	In order to fulfill your membership and store your membership information,  enable member login, inform about your membership, fulfill the obligations of the membership agreement.	Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract.
Identity (name,surname) Contact (e-mail address, address, telephone number)	In order to enable login to the Site Mobile Application without having to re-enter all the membership information again.	Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.
Contact (address, telephone number)	In case you save your address information to be used when shopping is requested on the Site/Mobile Application as a member	•      Consent.   •      Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract.
Transaction security (user identification information)	During membership, your transaction security data (your user identification information) automatically assigned for the realisation of your membership may be identified in our systems	•      Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject   •      Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract
Customer transaction (shopping date, delivery status, amount, shopping content) financial (payment details)	Information in order to provide you with the service of viewing your order history as a member.	•      Personal data of the parties to the contract is necessary, provided that it is directly related to the establishment or performance of a contract.
Identity information (name surname, gender), contact information (e-mail address, telephone number),	In order to ensure the accuracy and up-to-dateness of the information you will provide to Mavi during the membership process or through other communication channels with Mavi, and to update the information you have provided for your memberships.	•      It is necessary for compliance with a legal obligation to which the data controller is subject.   •      Personal data of the parties to the contract is necessary, provided that it is directly related to the establishment or performance of a contract.
Transaction security (user ID information)	In order to identify your membership in the system when you become a member of the Site / Mobile Application,	•      It is necessary for compliance with a legal obligation to which the data controller is subject.   •      Personal data of the parties to the contract is necessary, provided that it is directly related to the establishment or performance of a contract.
Identity (name, surname, gender), contact (e-mail address, mobile phone number, province, district), marketing (approaches to notifications/surveys/offers/campaigns within the Site and Mobile Application, habits, favorites, likes, behaviors, preferences, search movements, segments, past purchases, cookie records, cookie and ad identifier/ID information, communication preferences, survey responses, demographic information), transaction security (device ID, Mobile Application usage time, Mobile Application version information, brand, model, technical specification and operating system information of the device used, operator information used, communication preferences, site movements), finance (payment methods/channels and preferences, bank information where the payment is made), customer transaction (shopping) amount, purchase preferences), location (location)	For the purpose of providing you  with special opportunities and offers based on your Site membership and shopping, general or special personalized campaigns, advantages, promotions, creation of advertisements, organization of campaigns, contests, sweepstakes and other events, segmentation, profiling, reporting, marketing, and analysis studies Making advertisements and marketing/communication activities (the Site, pop-up display, personalized offers, customizing user screens, surveys, etc.) belonging to Site or other third-party environments, customer experience	•      Consent.   •      Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.
Identity (name, surname, signature), contact (e-mail address, telephone number, address), customer transaction (size of the product you have purchased, date, time, amount in order to provide, shopping content, customs number, delivery details), transaction security (log records and IP address) data regarding your shopping transaction, identity (name, surname, signature), contact (e-mail address, telephone number, address), customer transaction (size and shoe number of the product you have purchased, date, time, amount in order to provide, shopping content), transaction security (log records and IP address) data regarding your shopping transaction, as well as your finance (bank information and IBAN number) information if necessary for return transactions	If you make a purchase through online channels whether as a member or not, in order to carry out g the shopping transaction and issuing and sending the e-invoice/e-archive invoice related to your purchase,  order preparation, packaging, delivery note,  Shipping, updating delivery information, ensuring that your order is  delivered to you from our warehouses, distinguishing your records that we create in our system from those of other customers, after-sales carry out support services (modification, change, return, product inspection),	•      Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract   •      It is necessary for compliance with a legal obligation to which the data controller is subject
contact (e-mail address), customer transaction (body size information, shopping date, time, amount, shopping content, score data)	In case you shop via the Site as a member or without being a member of the Site, if you choose to participate in the satisfaction survey sent for the product you have purchased	Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.
Finance (Payment date, number of installments, payment status, cardholder name, card number (first 8, last 4 digits), card institution)	performing of the return transactions	•      Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract

 

• For the avoidance of doubt, in the above table the “purpose” and “legal basis” is indicative of the most probable reason(s) for processing your personal data with respect to the non-exhaustive list of types of personal data regularly processed by us.

 

• We collect your Personal Data directly from you or by actively obtaining your Personal Data ourselves (for example, through the use of tracking tools).

 

• WE WILL NOT PROCESS YOUR PERSONAL DATA IN A MANNER THAT IS INCONSISTENT WITH THE PURPOSE FOR WHICH WE HAVE COLLECTED THE PERSONAL DATA OR THE BASIS ON WHICH WE HAVE RELIED TO COLLECT YOUR PERSONAL DATA.

 

• WE WILL NOT PROCESS YOUR PERSONAL DATA IN A MANNER THAT IS INCONSISTENT WITH APPLICABLE LAWS AND REGULATIONS.

 

• If you fail to provide certain information, including Personal Data, when requested, we may not be able to provide you with information about our services and products.

2.         With Whom Do We Share Your Personal Data?

• We will only disclose or transfer your Personal Data for the purposes set out in this Privacy Policy to:
  • third-party service providers and sub-contractors who provide a service to us and help us run our business efficiently (including but not limited to marketing and advertising, data processing, IT and office services);
  • any member of our group; and
  • any competent authorities if we are legally required to comply with a request for data that includes your Personal Data.

 

• We do not sell, or share, your Personal Data with any third party except in accordance with applicable laws and regulations. This includes requesting, and obtaining, where required, your express, informed, and unconditional consent (or re-requesting, and re-obtaining the same, as the case may be).

 

• The foregoing notwithstanding, we may forward Personal Data to third parties for the purpose of making goods deliveries, processing debit/credit card payments, checking creditworthiness, combatting fraud, and any other legal purpose in connection therewith in addition to complying with the obligations we have made to you as our customer.

 

• To the extent we share any Personal Data, for any reason whatsoever, any such disclosure or transfer shall be done in accordance with any requirements for consent, including, if applicable, express consent.

 

 

3.         Countries to Which We Transfer Your Personal Data

• The Personal Data you submit may be transferred, stored, processed, and hosted outside of the country from which you may be accessing the Website, and may be transferred to countries which do not have data protection laws and regulations, or to countries where your privacy and other fundamental rights will not be protected as These, and all other transmissions, will remain secure and under our control.

 

• We will implement appropriate measures to ensure that your Personal Data remains protected and secure when such Personal Data is transferred outside of your home country (or country of residence, as the case may be) and in a manner that allows you to exercise your rights effectively under applicable laws and regulations.

If you would like further details of how your Personal Data is protected when transferred from one country to another then please email us at [privacy@mavi.com].

4.         Cookies

• Cookies are small pieces of information that your browser stores on your device when requested by a website.

 

• We may request, or require, that your browser store a cookie when you access this Website. For further information on the cookies that we use, rely upon, and/or collect, please see our Cookie Policy at [www.mena.mavi.com/pages/cookie].

5.         Keeping Your Personal Data Safe and Data Retention

• We take security issues We implement appropriate steps to help maintain the security of our information systems and processes and prevent the accidental destruction, loss, and/or unauthorized disclosure of the Personal Data we process.

 

• We will keep your Personal Data only for as long as is necessary to perform our services to you in accordance with this Privacy Policy.

 

• Beyond this, we will retain your Personal Data to respond to any queries, comments, or complaints, to improve our Website, or to comply with any legal obligations to which we may be subject.

 

• To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use and/or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether we can achieve such purposes through other means, and the applicable legal requirements.

 

• We will destroy or anonymize your Personal Data as soon as the purpose of collecting it, or the legal requirement for which we are required to keep the Personal Data, has

6.         Your Rights

• Under certain conditions, you may have the right to require us to:
  • provide you with further details on the use we make of your Personal Data;
  • provide you with a copy of the Personal Data we hold about you;
  • update any inaccuracies in the Personal Data we hold about you;
  • delete any of your Personal Data (for example, where we no longer have a lawful ground to use such Personal Data);
  • stop certain processing by withdrawing your consent (where processing is/was based on consent);
  • object to certain types of processing, including the profiling of data (for example, based on our legitimate interests unless our reasons for undertaking such processing outweigh any prejudice to your data protection rights under relevant law);
  • restrict how we use your Personal Data (for example, while a complaint is being investigated);
  • transfer your Personal Data to a third party in a standardized machine-readable format; and
  • any other legal right you may be entitled to under applicable data protection laws and regulations.

 

• You also have the right to object to the processing of Personal Data for direct marketing purposes.

 

• In the event you object to the processing of your Personal Data based on the grounds that our legitimate interest is insufficient to justify one or more processing acts, we will stop processing the Personal Data as soon as commercially practicable and in any event no later than as may be required by applicable law except for compelling legal grounds or when necessary for the exercise, or defense, of potential claims.

 

• To exercise any of the foregoing rights, please email us at [privacy@mavi.com]. Subject to any overriding legal obligations, requirements and/or exemptions, we will respond to your request as soon as commercially practicable, and, in any event, no later than response requirements prescribed by applicable law, unless we require further information from We may ask you to provide additional information, including proof of your identity, to adequately respond to your queries.

7.         Your Right to Complain

• If you are not satisfied with our use of your Personal Data in respect of this Website or our response to any request by you to exercise your rights, or if you think that we have breached any relevant data protection laws, then please contact us at [privacy@mavi.com].

 

• You may in addition have the right to complain to any regulatory authority that supervises the processing of your Personal Data, including the data protection authority in the country in which you reside.

8.         Children

• We are committed to protecting the privacy needs of children, and we encourage parents and guardians to take an active role in their children’s online activities and interests.

 

• We do not knowingly collect information from children, and we do not target our Website to children.

9.         Local Differences

• This Website, and the Privacy Policy, is designed for data subjects accessing the Website within the Gulf Cooperative Council (the “GCC”) and for the benefit of data subjects residing in the GCC.

 

• While this Privacy Policy describes the data protection practices adopted by us for users of this Website generally within the jurisdictions within the GCC, we recognize, and acknowledge, that applicable data protection laws and regulations may vary depending on factors related to you, and our operations in some countries may mean that we are subject to different, or additional, local data privacy and protection rules, regulations, and/or requirements.

 

• To the extent there is a conflict between this Privacy Policy and applicable data privacy and protection rules, regulations, and/or requirements, we will use all commercially reasonable efforts to resolve the conflict in good faith.

10.      Hyperlinks and Third-Party Sites

• Our Website may provide links to third-party websites for your convenience. If you access those links, you may be asked, or required, to leave our Website. If you elect to leave our Website to move to a third-party website, we wish to inform you that we do not control such third-party websites, or their privacy practices, which may differ from ours. We do not endorse, or make any representations, about any third-party websites.

 

• This Privacy Policy does not cover any data, including Personal Data, that you choose to give to unrelated third parties. We encourage you to review the privacy policy of any company before submitting any of your data, including personal data.

 

• Some third-party companies may choose to share their data, including personal data, with us; unless otherwise mentioned, the sharing of such data, including personal data, with us is governed by such third-party company's privacy policy.

11.      Notification of Changes

• We may be required to update or change our Privacy Policy from time to time for legal or practical reasons. Any such update or change shall be done in accordance with applicable laws and regulations.

 

• We will upload an updated Privacy Policy on this Website as soon as possible in the event of a change. We will notify you of any changes to the Privacy Policy in accordance with applicable law, include any advance notice that may be required by law prior to effectiveness of the change.

 

12.      Contacting Us

• This Privacy Policy sets out in broad terms how we handle your Personal Data and safeguard your

 

• If you have any questions relating to our Privacy Policy, please send an email to the following address: [privacy@mavi.com].