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PRIVACY POLICY

Last updated: 6.15.2023

 

Fulya Kocak, LLC ("us", "we", or "our") operates www.fulyakocak.com ​(the "Site"). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site. 

We use your Personal Information only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this policy.

The target audience of this site is not children under the age of 16. This website or mobile app is not designed for use by children under the age of 16 and we do not knowingly solicit personal data from anyone under the age of 16. If you are under the age of 16, do not access our website or related products and services. If you become aware that we have collected data from anyone under the age of 16, please contact us so that we may delete that data.

INFORMATION COLLECTION & USE

While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to your name ("Personal Information"). We do not collect and sell any Personal Information you may provide. 

DATA

Personal Data is information that can be used to identify you specifically, including your name, shipping address, email address, telephone number, or demographic information like your age, gender, or hometown. You consent to giving us this information by providing it to us voluntarily on our website or any mobile application. You provide some of this information when you register with or make purchases from our website. You may also provide this information by participating in various activities associated with our site, including responding to blogs, contacting us with questions, or participating in group training. Your decision to disclose this data is entirely voluntary. You are under no obligation to provide this information, but your refusal may prevent you from accessing certain benefits from our website or from making purchases.

Derivative data is information that our servers automatically collect about you when you access our website, such as your IP address, browser type, the dates and times that you access our website, and the specific pages you view. If you are using a mobile application, our servers may collect information about your device name and type, your phone number, country of origin, and other interactions with our application. Derivative data may also include data collected by third-party service providers, such as advertising and analytics providers, and may include cookies, log data, or web beacons. Cookies are discussed more fully below. Derivative data collected by third-party service providers generally does not identify a specific individual. 

Financial data is data that is related to your payment method, such as credit card or bank transfer details. We collect financial data in order to allow you to purchase, order, return, or exchange products or services from our website and any related mobile apps. We store limited financial data. Most financial data is transferred to our payment processor, Stripe, and you should review these processors’ Privacy Policy to determine how they use, disclose, and protect your financial data. As a courtesy, Stripe's Privacy Policy can be found here: https://stripe.com/privacy.

We may access personal information from social networking sites and apps, including Facebook, Instagram, Linkedin, Twitter, Snapchat, or other social networking sites or apps not named specifically here, which may include your name, social network username, location, email address, age, gender, profile picture, and any other public information. If you do not want us to access this information, please go to the specific social networking site and change your privacy settings.

If you use our website via a mobile device or app, we may collect information about your mobile device, including device ID, model and manufacturer, and location information.

On occasion, you may give us additional data in order to enter into a contest or giveaway or to participate in a survey. You will be prompted for this information and it will be clear that you are offering this kind of information in exchange for an entry into such a contest or giveaway.

 In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this Site.

USE OF DATA

Your information allows us to offer you certain products and services, including the use of our website, to fulfill our obligations to you, to customize your interaction with our company and website, and to allow us to suggest other products and services we think might interest you. We generally store your data and transmit it to a third party for processing. However, to the extent we process your data, we do so to serve legitimate business interests (such as providing the opportunity to purchase our goods or services and interact with our website or mobile app).

Specifically, we may use the information and data described above to:

  1. Create and administer your account;
  2. Deliver any products or services purchased by you to you; 
  3. Correspond with you; 
  4. Process payments or refunds; 
  5. Contact you about new services that we think you will be interested in; 
  6. Interact via social media; 
  7. Send newsletters or other updates about our company or website;
  8. Deliver targeted advertising; 
  9. Request feedback; 
  10. Notify you of updates to our product and service offerings; 
  11. Resolve disputes and troubleshoot any problems; 
  12. Administer contests or giveaways; 
  13. Generate a profile that is personalized to you, so that future interactions with our website will be more personal;
  14. Compile anonymous statistical data for our own use or for a third party’s use;
  15. Assist law enforcement as necessary; 
  16. Prevent fraudulent activity on our website or mobile app; and
  17. Analyze trends to improve our website and services.

LOG FILES

Like many other websites, we make use of log files. These files merely log visitors to the site-usually a standard procedure for hosting companies and a part of hosting services’ analytics. The information inside the log files includes internet protocol (IP) addresses, browser type Internet Service Provider (ISP), date/time stamp, referring/exit pages, and possibly the number of clicks. This information is used to analyze trends, administer the site, track user’s movement around the site, and gather demographic information. IP addresses and other such information are not linked to any information that is personally identifiable.

COOKIES

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer's hard drive.

Like many sites, we use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.

SECURITY

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

PROCESSING YOUR INFORMATION

For the most part, we do not process your information in-house, but give it to third-party processors for processing. For example, when PayPal takes your payment information, they are a third-party processor. They process your payment and remit the funds to us. So in many instances, it will be necessary for us to transmit your information to a third-party processor, as we do not have the capability to perform these functions. 

We may, from time to time, process your data internally. The legal basis for this processing is both your consent to the processing, our need to conduct legitimate business interests, and to comply with legal obligations. Our purposes in processing this information, if we do, is to administer, maintain, and improve our website and offerings, to enter into contracts with you, to fulfill the terms of those contracts, to keep records of transactions and interactions, to be able to provide you with goods and services, to comply with our legal obligations, to obtain professional advice, and to protect the rights and interests of our company, customers (including you), and any third parties. We may process the following data:

  1. Data associated with your account, such as name, address, email address, and payment information;
  2. Data about your usage of our website, such as Your IP address, geographical information, how long you accessed our website and what you viewed;
  3. Data related to your personal profile, such as name, address, profile picture, interests and hobbies, or employment details;
  4. Data that you provide us in the course of using our services;
  5. Data that you post on our website, such as comments or responses to blogs;
  6. Data that you submit to us when you make an inquiry regarding our website or offerings;
  7. Data related to your transactions with us, including your purchase of goods or services. This information may include contact details and payment information;
  8. Data that you provide to us when you subscribe to emails or newsletters, including your email address and contact information;
  9. Data that is submitted to us via correspondence, such as when you email us with questions; or 
  10. Any other data identified in this policy, for the purpose of complying with our legal obligations, or to protect the vital interests of you or any other natural person.

OTHER IMPORTANT INFORMATION

FOR VERMONT RESIDENTS: We will not share information we collect about you with nonaffiliated third parties, except as permitted by Vermont law, such as to process your transactions or to maintain your account.

FOR CALIFORNIA RESIDENTS: We will not share information we collect about you with nonaffiliated third parties, except as permitted by California law, such as to process your transactions or to maintain your account. We will limit sharing among our companies to the extent required by California law.

FOR NEVADA RESIDENTS: We are providing this notice to you pursuant to Nevada law. If you prefer not to receive marketing calls from us, you may be placed on our internal Do Not Call List by contacting us at [email protected]. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protections, Office of the Nevada Attorney General, 555 E. Washington Street, Suite 3900, Las Vegas, NV 89101, phone number (702) 486-3132, email [email protected].

FOR COLORADO, CONNECTICUT, VIRGINIA AND UTAH RESIDENTS: We are providing you with information about your privacy rights under the Colorado Privacy Act, the Connecticut Data Privacy Act, the Virginia Consumer Data Protection Act and the Utah Consumer Privacy Act.

This section shall be effective for the residents of those States on the dates set forth below:

Effective January 1, 2023, for residents of the State of Virginia

Effective July 1, 2023, for residents of the States of Colorado and Connecticut

Effective December 31, 2023, for residents of the State of Utah

For purposes of this section, "residents", "consumers" or "you" means individuals of those states who are acting in their individual or household context. This section does not apply to individuals acting in their commercial or employment context.

  1. Personal Information we collect
    You have a right to know the categories and types of personal information we collect about you. 
  2. Categories of sources from which we collect personal information
    You have a right to know the categories of sources from which we collect your personal information. 
  3. Our processing of your personal information
    You have the right to know how we process and use your personal information.
    For residents of the State of Virginia, to the extent that we maintain de-identified data, we take reasonable measures to ensure that de-identified data cannot be associated with a natural person, we publicly commit to maintaining and using de-identified data without attempting to re-identify the data, and we contractually obligate any recipient of the data to comply with the same obligations.
  4. Disclosure of Personal Information
    You have the right to know if we share your personal information with any third parties. 
  5. No Sale of Data or Use of Data for Targeted Advertising
    We do not sell your personal information and we do not use your data for targeted advertising (as that term is defined by your applicable state law). We may send you advertising in response to your request for information or feedback or based on your activities with our website, including your search queries and visits to our website. However, we will not send you targeted advertising based on your activities across non-affiliated websites to predict your preferences or interests.
  6. Your Rights
    Where we act as the Controller of your personal information (as opposed to a Processor as those terms are defined in your applicable State law), you have the right to submit a request to us for the following:
    1. Your right to access. You have the right to know if we process your personal information and have access to such information and certain details of how we use it.
    2. Your right to correct. We take reasonable steps to ensure that information we hold about you is accurate and complete. However, you have the right to request that we correct any inaccurate personal information that we have about you.
    3. Your right to delete. You may have the right to request that we delete your personal information where we act as a controller. This right is subject to several exceptions and we may deny your deletion request if retaining the information is necessary for us or our processors to:
      1. Complete the transaction for which we collected the personal information and take actions reasonably anticipated within the context of our ongoing business relationship with you or our client;
      2. Detect bugs or errors in our websites, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
      3. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
      4. Comply with a legal obligation; or
      5. Make other internal and lawful uses of that information as permitted by law or that are compatible with the context in which we collected it.
    4. Your right to restriction of processing (opt-out). You have the right to opt-out of processing your personal information for purposes of profiling in furtherance of any automated processing of your data that produce legal or similarly significant effects concerning you. (This right only applies to residents of the States of Colorado, Connecticut and Virginia.)
    5. Your right to data portability.You have the right to obtain a copy of your data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to a third party.
    6. Your right to non-discrimination and no retaliation. We will not discriminate or retaliate against you for exercising any of your rights, including but not limited to, by denying you goods or services, charging you different prices for goods or services, or providing you a different level or quality of goods or services.
    7. Your right to restrict the processing of sensitive information.Unless we are processing your sensitive information pursuant to any of the legal exemptions listed below or as otherwise allowed by law:

For residents of the States of Connecticut, Virginia and Colorado, we will not process your sensitive information without first obtaining your consent; and

For residents of the State of Utah, we will not process your sensitive personal information without providing you with notice and an opportunity to opt out.

EXERCISING YOUR RIGHTS

You may exercise your rights described above by submitting a request to us by:

Emailing us at [email protected].

AUTHENTIFICATION PROCESS

We will only fulfill requests when we can verify your identity and confirm that you are authorized to make such a request.

Only you, as the parent or legal guardian on behalf of your minor child, or your authorized agent, guardian or conservator may make a request related to personal information. If an authorized agent, legal guardian or conservator submits the request, we may require your written permission to do so and may require additional information to authenticate your identity. We may deny a request by an authorized agent, legal guardian or conservator who does not submit proof of authorization to act on your behalf.

We will only use the personal information you provide in a request to verify your identity or authority to make the request.

RESPONSE TIMING & FORMAT 

We will respond to an authenticated request within forty- five (45) days of its receipt, and will notify you within those forty-five (45) days if we require more time to respond and the reasons for the additional time.

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.

If we cannot comply with a request or a portion of the request, we will include the reasons in our response.

For residents of the States of Colorado, Connecticut and Utah, you may make one request within a twelve-month period at no charge. For residents of the State of Virginia, you may make a request up to two (2) times within a twelve (12) month period at no charge. We reserve the right to charge a fee to process or respond to any request that we consider 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.

RIGHT TO APPEAL

You have the right to appeal our decision within a reasonable period of time after receipt of our response. You may appeal our decision by sending us an email at [email protected]. We will respond to your appeal within 60 days of receipt (45 days of receipt for residents of Colorado) and will inform you of any decisions and the reasons for such decisions.

Please note that in certain cases we may collect your personal information as a processor (as opposed to a controller, as those terms are defined in your applicable state privacy law) pursuant to a contract we have with a commercial client (the controller) to provide a service. In such a case, we are required to collect and process your information only based on the instructions received from the controller. Should you direct your requests to exercise your rights to us, we may be required to share your request with the controller, who is the party responsible under your applicable state privacy law for receiving, authenticating and responding to your requests.

EXEMPTIONS 

This section (Notice of Colorado, Connecticut, Virginia and Utah Privacy Rights) does not apply to certain entities and data that are exempt from your applicable state privacy law, including but not limited to the following: covered entities, business associates and protected health information governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act (HITECH); financial institutions and personal information subject to the Gramm-Leach-Bliley Act (GLBA); and personal information collected, processed, sold, or disclosed pursuant to certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Family Educational Rights and Privacy Act, the Farm Credit Act and the Driver's Privacy Protection Act of 1994 (DPPA).

State laws may also provide you with specific privacy protections. We will comply with applicable state laws with respect to our use of your information.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we may notify you either through the email address you have provided us, or by placing a prominent notice on our website.

NEWSLETTER PRIVACY

We offer the opportunity for you to volunteer certain information to us that is used for email and marketing purposes. This information includes, but is not limited to your and email. You will have an opportunity to unsubscribe from any future communications via email, but we reserve the right to maintain a database of past email subscribers. We reserve the right to use this information as reasonably necessary in our business and as provided by law. Your information will be shared with reasonably necessary parties for the ordinary course of conducting our business, such as through Facebook ads or Google Pay Per Click marketing campaigns.

We do not ever sell your information to third parties.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at [email protected].