Website Policies
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PRIVACY POLICY
Introduction
Last Updated: January 25, 2024
Tiffany TCO Turkey Mücevherat Ticaret Limited Şirketi Privacy Notice
Please click here to access the list of Tiffany Group retail affiliates, as referenced in this Privacy Notice.
TCO Turkey Mücevherat Ticaret Limited Şirketi (“Tiffany” or “Company”) acts as the data controller pursuant to the Personal Data Protection Law numbered 6698 (“Law”). We at Tiffany, along with our subsidiaries and affiliates, parent companies (collectively, the “Tiffany Group”), respect your concerns about privacy.
References in this Privacy Notice to “we”, “us”, “our”, “Tiffany” are references to the entity that is responsible for the processing of your personal information which in the case of Turkey is TCO Turkey Mücevherat Ticaret Limited Şirketi. References in the Privacy Notice to “personal information” are references to “personal data” term defined under the Personal Data Protection Law No.6698.
This Privacy Notice describes the types of personal information we collect about our consumers, why we process such personal information, how we use the personal information, how we collect such personal information and on which legal basis, with whom we share it and the choices and rights available to our consumers regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.
Tiffany Group’s privacy practices may vary among the countries/regions in which we operate to reflect local practices and legal requirements. You can view certain country/region-specific information below:
Americas
Asia/Pacific
Europe
This Privacy Notice applies to the personal information we obtain as TCO Turkey Mücevherat Ticaret Limited Şirketi via your transactions and interactions with Tiffany, including through your use of Tiffany websites, mobile applications, social media pages and other platforms that reference this Privacy Notice (“Online Channels”); your visits to our stores, including when you complete our client information collection cards, and when you connect with us via telephone, at our events and through surveys (“Offline Channels”); and through our third-party sources, including advertising and social media networks (collectively, the “Channels”).
Information we obtain
We collect personal information about you through various Channels as described above. The types of personal information we collect include:
- contact information (such as name, postal address, email address, and mobile or other telephone number);
- username and password;
- payment information (such as your payment card number, expiration date, authorization number or security code, delivery address, and billing address);
- client care information (such as client service inquiries, comments, and repair history);
- photographs, comments and other content you provide;
- information regarding your personal or professional interests, date of birth, marital status, demographics, and experiences with our products and contact preferences;
- purchase and transaction information;
- contact information you provide about friends or other people you would like us to contact;
- location data (such as data derived from your IP address, country/region and/or zip code) and the precise geolocation of your mobile device where we have provided notice and choice, as appropriate;
- Information you provide to us through the automated virtual assistant and live chat features on our Online Channels;
- clickstream data and other information about your online activities (such as information about your devices, browsing actions, actions you take on our Online Channels and usage patterns), including across the Online Channels and third-party websites, that we obtain through the use of cookies, web beacons and similar technologies (see our Cookie Policy);
- video information, including CCTV footage collected in stores;
- recordings of calls and information you provide us through Tiffany’s contact center;
- information we may obtain from our third-party service providers; and
- other personal information we obtain through our Channels.
Purpose of processing of personal information
Your collected personal information may be processed for the following purposes in accordance with the main principles and personal information processing conditions stipulated in the articles 5 and 6 of the Law:
Within the scope of benefiting from the products or services provided by Tiffany:
· Ordering products and services through purchases our stores, packaging, delivery, after-sales (return, exchange, exercising withdrawal right etc.) of the purchased products, transactions/processes, carrying out contract processes, issuing invoices and documents arising from tax legislation, carrying out payment processes, and ensuring payment security, managing customer relations, and evaluating and responding to customer requests, complaints, wishes and questions, according to your likes, usage habits and needs:
- Creating an account within the scope of account management, determination of fulfilment of the qualification requirements, inquiring about an account, changing/updating account information, sending password and confirmation code, informing you about the matters, such as advantages, etc., and allowing you to benefit from them, fulfilling any obligations arising from account,
- Customizing the products and services provided by Tiffany according to your likes, usage habits and needs, advertising and carrying out marketing/communication activities regarding Tiffany on the Online Channels or other third-party online environments,
- Conducting segmentation, reporting, profiling, marketing and analysis studies,
- Sending commercial electronic messages, such as advertisements, promotions, campaigns, etc., to the contact information you have provided.
Within the scope of carrying out the business activities of Tiffany:
- Carrying out accounting, tax and finance processes,
- Carrying out information security processes,
- Fulfilling our regulatory obligations, and
- Resolving legal disputes, or providing information and documents to authorized public organizations and institutions, private persons, and judicial authorities, or relevant police forces, upon request, in accordance with the relevant legislation, and fulfilling our other legal obligations.
Collection method of your personal information:
Your personal information shall be collected (i) electronically, in case you contact Tiffany in electronic environment through Online Channels such as website, mobile device application, social media pages and other platforms (visiting them, creating an account, filling out online surveys, etc.), (ii) physically, in case you visit our stores, connect us via e-mail, telephone, SMS, call center, at our events and through physical surveys or (iii) through the Channels such as our third-party sources, and recording information/documents regarding you provided by public organizations, institutions and judicial/administrative authorities, in order to enable you to benefit from the products and services provided by Tiffany.
We use cookies, web beacons (including pixels and tags), web server logs and other technologies that collect certain information about you by automated means through our Online Channels, including when you visit our websites, interact with our emails, use our apps, or interact with Tiffany-related ads, content, tools, widgets or plug-ins. You can learn more about these technologies and how to manage your preferences by visiting our Cookie Policy
The providers of third-party apps, tools, widgets and plug-ins on our Online Channels, such as Facebook “Like” buttons, also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, Tiffany is not responsible for these providers’ information practices.
How do we use the information we obtain and what are the legal basis for obtaining such information?We use the personal information we obtain as described in this policy and rely on a number of legal bases to do so as described further below, including:
- performance of a contract with you;
- our legitimate business interests;
- compliance with a legal obligation, a court order, or to exercise or defend legal claims; or
- your consent to the processing, which you can revoke at any time.
We use the information we obtain to perform a contract with you or to take steps at your request prior to entering into a contract, including to:
- transact with you and provide various products and services to you;
- process and fulfill orders in connection with our products and services and keep you informed about the status of your order; and
- provide client support (including repairs, alterations, cleaning and other services);
We use the information we obtain based on your explicit consent, including to;
- create and manage your account with Tiffany;
- transfer your personal information to abroad as detailed in this Privacy Notice;
- Sending advertisements, promotions, campaigns and similar commercial electronic messages to your contact information;
- Sending you promotional materials and other communications (including thank you notes, special occasion reminders and other communications from sales professionals with whom you’ve engaged);
- Communicate with you via email, postal mail, phone and other means about, and to administer your participation in, special events, contests, sweepstakes, programs, offers, surveys and market research; and
- Customizing the products and services offered by Tiffany according to your tastes, usage habits and needs.
We use the information we obtain on the basis of our legitimate interests, which we can describe further upon request, including to:
- operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products and client base; performing data analytics; and performing accounting, auditing and other internal functions);
- provide customer support services through the automated virtual assistant and live chat features on our Online Channels and maintain transcripts of chat communications.
- reduce credit risk and manage collections;
- verify your identity;
- protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
- provide customer support services through Tiffany’s contact center and maintain recordings of the calls for quality control, training purposes and dispute resolution purposes.
- comply with and enforce relevant industry standards, contractual obligations and our policies; and
- respond to your inquiries.
In addition, we process your personal information to comply with and enforce applicable legal requirements to which we are subject, including providing information and documents to authorized public institutions and organizations, private individuals and judicial and law enforcement authorities; and for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We also use the information in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law.
Use of cookies and other technologies
Where we have obtained your consent to the extent required by applicable law, we use information collected through cookies, web beacons (including pixels and tags), web server logs and other automated means for the purposes described in our Cookie Policy.
We also use third-party analytics services on our Online Channels, such as those of Google Analytics, Adobe Experience Cloud, TikTok and Meta, which use cookies and similar technologies to collect data (such as IP address and other behavioral and technical data attributes) to evaluate use of, navigation and interaction with our Online Channels. To the extent required by applicable law, we will obtain your consent before using cookies for analytics purposes. To learn more about these analytics services and how to opt out (if the service offers the opportunity to do so), please visit the relevant websites listed here:
- Google Analytics: http://www.google.com/analytics/learn/privacy.html
- Adobe Experience Cloud: http://www.adobe.com/privacy/analytics.html#1
- TikTok: https://www.tiktok.com/legal/page/row/privacy-policy/en
- Meta: http://www.aboutads.info/choices
We may also use a third-party session replay service provided by Contentsquare that records users’ interactions with our Online Channels, including users’ clicks, mouse movements and scrolls. To learn more about Contentsquare, please visit https://contentsquare.com/services-privacy-policy/ and https://contentsquare.com/privacy-center/general-privacy-statement/.
Interest-based advertising
When you use our Online Channels, both we and certain third parties (such as our advertising networks, digital advertising partners and social media platforms) collect information about your online activities, over time and across third-party websites (such as on websites that serve our ads). We may use such information to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. You may see certain ads on other websites because we engage third-party ad buying networks (such as Facebook, Rubicon and Twitter). Through such buying networks, we can target our messaging to users through demographic, interest-based and contextual means. The information our ad networks may collect on our behalf includes data about your visits to websites that serve Tiffany advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in these ad networks. This process helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising, click here. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.
Our Cookie Policy provides details about the purposes of this data collection via cookies and other technologies and how to exercise your choices (such as changing your cookie preferences).
Information we share
We do not disclose personal information we collect about you, except as described in this Privacy Notice. We share personal information with service providers who perform services on our behalf based on our instructions in compliance with the rules regarding transfer of personal information and data processing conditions regulated under the Law. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. These service providers include entities that process credit card payments, manage and reduce our credit risk, verify information, fulfill orders, and provide web hosting, fraud prevention, analytics and marketing services. We share your personal information with service providers residing in the country/region based on our legitimate interest. We share your personal information with service providers residing abroad, including those that are listed here. We also share your personal information within the Tiffany Group worldwide for the purposes described in this Privacy Notice.
In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, if required by the relevant legislation or legal process, (iii) for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer (or contemplate the sale or transfer of) all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation)
How long we retain personal information
To the extent permitted by applicable law, we typically retain personal information we obtain about you for as long as it is needed (1) for the purposes for which we obtained it, in accordance with the terms of this Privacy Notice, which generally means that we will keep your personal information for the duration of our relationship or as long as you keep your account open with us; or (2) to take into account applicable statute of limitation periods and comply with mandatory applicable laws. As described in the “Your Rights and Choices” section of this Privacy Notice, to the extent provided by the law of your jurisdiction, you may request that we delete your information or restrict the processing of such information by contacting us as indicated below.
Your rights and choices.
- Pursuant to Article 11 of the Law, you have the following rights as the data owner:
- to learn whether your personal information has been processed,
- to request information regarding the processing in case your personal informationhas been processed,
- to learn the purpose of processing your personal informationand whether the personal information is used in accordance with the purpose,
- to know the third parties to whom your personal information is transferred domestically or abroad,
- to request correction of your personal information in case of incomplete or incorrect processing,
- in accordance with Article 7 of the Law, to request the deletion or destruction of your personal information in accordance with the conditions stipulated under the Law,
- to request notification of the correction, deletion or destruction of your personal information to third parties to whom your personal information has been transferred,
- to object to the occurrence of a result that is against you due to the analysis of your processed personal information solely through automated systems,
- to request compensation for damages arising from the unlawful processing of your personal information.
We offer you certain choices in connection with the personal information we collect about you, to the extent required by law, such as how we use the information and how we communicate with you. To update your preferences, contact us at any time to remove your information from our mailing lists, exercise your rights or submit a request, please contact us as indicated in the How to Contact Us section of this Privacy Notice. You can also unsubscribe from our mailing lists by following the “Unsubscribe” link in our emails. To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, update, amend, or delete your information, or that we comply with your other requests, within the scope of your above applicable rights by contacting us as indicated below.
To exercise your rights, you can submit to us your application/request regarding your above-mentioned rights by contacting us as indicated in the “How To Contact Us” section of this Privacy Notice or other methods in accordance with the legislation. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information or complying with your request.
We shall conclude your request, free of charge, within the shortest possible time depending on the nature of your request, and within, at most, thirty (30) days. However, if the procedure requires additional costs, a fee shall be charged in accordance with the fees set out in the tariff determined by the Personal Data Protection Board.
When you use our Online Channels, both we and certain third parties (such as our advertising networks, digital advertising partners and social media platforms) may collect personal information about your online activities, over time and across third-party websites. Certain web browsers allow you to instruct your browser to send Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked. While our Online Channels are not designed to respond to all types of DNT signals or similar mechanisms from browsers as there is no common, industry-accepted standard for doing so, when we recognize a relevant DNT signal, we aim to suppress the third-party tags that are used to recognize your computer once you navigate away from our site and which are used to present you with Tiffany advertisements. In our Cookie Policy, we provide information about how you can manage your cookie preferences and the choices you can make in connection with the personal information we collect about you through automated means. To learn more about managing your preferences in relation to the data we collect on an automated basis, please visit our Cookie Policy.
Data transfers
In compliance with the rules regarding transfer of personal information and data processing conditions regulated under the Law, we transfer the personal information we collect about you to the countries outside of the Turkey in which the information originally was collected, including the jurisdictions in which our affiliates, subsidiaries, parent companies and service providers operate. When we transfer your information to other countries, we will implement appropriate safeguards to help ensure that we protect that information as described in this Privacy Notice.
How we protect personal information
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Links to non-Tiffany sites and services
For your convenience and information, our Online Channels may provide links to non-Tiffany sites, apps and services that may be operated by companies not affiliated with Tiffany. These companies may have their own privacy notices or policies as well as terms and conditions of use, which we strongly suggest you review. Our products and services also may be made available to you through third-party platforms (such as providers of app stores) or through other third-party channels. We are not responsible for the privacy practices of any non-Tiffany sites, apps or services.
Updates to our Privacy Notice
This Privacy Notice (including any addenda) may be updated periodically to reflect changes in our personal information practices. For significant changes, we will notify you by posting a prominent notice on our website indicating at the top of the Notice when it was most recently updated.
How to contact us
You can update your preferences, submit a request or ask us questions about this Privacy Policy by emailing us at privacy@Tiffany.com.