Privacy Policy

Privacy Policy for the Processing of Personal Data pursuant to Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016 (GDPR). Effective as of 02/08/2023

INTRODUCTION

This privacy policy complies with the GDPR and the Italian Privacy Code (Legislative Decree of 30 June 2003, no. 196). It has also been drafted based on the Privacy Authority’s Guidelines, especially the Anti-Spam Guidelines issued on 4 July 2013.

Data Controller

The Data Controller is Esisto Denim Ltd, with its registered office at Valikonagi Cad. Elif Sokak 4/2 Bakirköy/Istanbul.
Email: info@klshjeans.com | Phone: +905346438622.
Website referenced by this privacy policy: https://klshjeans.com/ (hereafter referred to as the “Website”).
The Data Controller has not appointed a DPO (Data Protection Officer). Therefore, any request for information can be sent directly to the Data Controller.

GENERAL INFORMATION

This document describes how the Data Controller processes your personal data provided on the Website. Below, the primary methods of processing your personal data are outlined, including the legal basis, whether providing data is mandatory, and the consequences of not providing data. To clarify your rights, it is specified when certain types of personal data processing are not performed.

Registration on the Website

The information and data requested during registration will be used to allow access to the reserved area of the Website and to enable the use of online services offered by the Data Controller to registered users.

Legal Basis: The necessity of the Data Controller to take pre-contractual measures requested by the data subject.
Optional Provision: Providing this data is optional. However, refusal to provide the data will make it impossible to register on the Website.
You can also register on the Website using external services, in which case your registration data will be shared with the companies providing those external services solely to enable registration on the Website. The legal basis for this processing is the legitimate interest of the Data Controller in facilitating registration via external services. Providing data for this purpose is optional, but refusal will prevent registration using external services.

Purchases on the Website

Your personal data will be processed to allow purchases on the Website. When an online purchase order is placed, data will be processed to finalize the purchase contract and manage related operations (and, if necessary, fulfill tax obligations under applicable laws).

This includes communications via automated tools (e.g., SMS and/or WhatsApp) for tracking and order updates.
Legal Basis: The Data Controller’s obligation to fulfill the contract with the data subject or comply with legal obligations.

The Data Controller may process your email for “soft-spam” purposes, as allowed under Article 130 of the Privacy Code. This means that, limited to the email provided during a purchase, the Data Controller may send direct offers for similar products/services, provided you do not object.
The legal basis is the legitimate interest of the Data Controller, equivalent to the user’s interest in receiving such communications.

Additionally, the Data Controller may send emails reminding users to complete purchases.

Legal Basis: The Data Controller’s legitimate interest in sending such reminders.

Responding to Requests

Your data will be processed to respond to your requests for information.

Optional Provision: Providing this data is optional, but refusal will prevent the Data Controller from responding to your inquiries.
Legal Basis: The Data Controller’s legitimate interest in responding to user requests, which aligns with the user’s interest in receiving responses.

General Marketing

With your consent, the Data Controller may process your personal data to send promotional materials and/or newsletters about its own or third-party products.

Legal Basis: Your consent.
Optional Provision: Failure to provide consent will prevent you from receiving promotional materials or newsletters.

Profiling

The Data Controller does not perform profiling with your personal data. Therefore, you will not receive targeted advertising or newsletters based on your specific interests.

Data Transfer

The Data Controller does not transfer your personal data to third parties.

Geolocation

The Website does not use tools to geolocate users’ IP addresses.

Curriculum Vitae

The Website does not allow users to send resumes; therefore, such data is not processed.

Appointment Booking

The Website does not offer third-party appointment booking systems. You may contact the Data Controller directly using the contact details provided above.

SPECIFIC PRIVACY NOTICE

Article 1: Methods of Processing

1.1 Your personal data will mainly be processed using electronic or automated tools to ensure security and confidentiality in compliance with the GDPR.
1.2 Data will be processed in a manner that is relevant and non-excessive concerning the services provided.
1.3 “Special data” (e.g., revealing racial or ethnic origin, religious beliefs, health, or sexual orientation) is not processed on the Website.

Article 2: Communication of Personal Data

The Data Controller may share your data with specific categories of recipients:

Public authorities as required by law.
Consultants and legal advisors.
Employees or collaborators to operate the Website.
External companies managing CRM or communication tools for marketing purposes.

Article 3: Data Retention

3.1 Personal data will only be retained as long as necessary to provide services or comply with legal obligations (e.g., financial records for 10 years).
3.2 For marketing purposes, data will be retained until consent is revoked.

Article 4: Data Transfer

The Data Controller operates within the EU and ensures compliance with GDPR. Transfers to non-EU countries are based on adequacy decisions (e.g., Switzerland or the USA).

Article 5: Data Subject Rights

You have the right to:

Access, rectify, or delete your data.
Withdraw consent at any time.
Lodge a complaint with a supervisory authority.

Article 6: Modifications

The Data Controller reserves the right to amend this privacy policy. Users are encouraged to regularly review the policy for updates.