Privacy Policy

Last Updated March 01, 2024 

This Privacy Policy ( “Policy”)  for Karadere Turizm Organizasyon Limited Sirketi ( “Cleopatra Ink”, “Company”, “we” and “us” ) describes how and why we might collect, store, use and/or share (“process”) your personel data and your choices about your data within the scope of this Policy when you use our services (“ Services”), in a simple and understandable manner such as you when:

• Visit our website at http://www.cleopatraink.com, or any website of ours, apps that links to this privacy policy

• Engage with us in other related ways, including any sales, marketing or events

Ouestions or concerns? 

Our privacy policy is designed to help you understand your privacy rights and choices. If you do not agree with our policies and practices, please refrain from using our services. . If yo still have any questions or concerns, please contact us at [email protected]. 

Where This Policy Applies ? 

This Policy applies to our websites, apps, events, and other services operated by Cleopatra Ink. To enhance clarity, we've provided links to this Policy on all relevant services. You can obtain more detailed information about any of these topics by clicking the link following each key point or by using our table of contents below to navigate to the specific section you are seeking. Additionally, you can also refer to the 'TABLE OF CONTENTS' for quick access.

Certain services may necessitate their own distinct privacy policy (e.g., some events, promotions). If a specific service has its own privacy policy, then that privacy policy, not this Policy, shall be applicable.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. IS YOUR INFIRMATION TRANSFERRED INTERNATIONALLY?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. WHAT ARE YOUR PRIVACY RIGHT?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO WE MAKE UPDATES TO THIS POLICIY?
13. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT PERSONAL INFORMATION DO WE PROCESS ? 

• Personal information you disclose to us
  • Names

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and services, participate in activities on the Services, or contact us in any other way.

Personel Information Provided by you ;

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Phone numbers
• Email addresses
• Mailing addresses
• Usernames
• Passwords
• Contact preferences
• Contact or authentication data

Sensitive Information:

We do not process sensitive information.

Social Media Login Data: 

We may provide you with the option register with us using your existing social media account details, like your Facebook, Twitter, or other social media account described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

All personal information that you provide to us must be true, complete and accurate and you must notify us od any changes to such personal information.

Information authomatically ( Cookies or Other Data Collection Technologies) collected :

In Short: Some information – such as your Internet Protocol (IP) address and/or browser and device characteristic – is collected automatically when you visit our Services.

When automatically collect certain infromation when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information about how and when you use our Services, and other techinical information. This information is primarily need to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses , we also collect information through cookies and similer Technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers authomatically collect when Access or use our Services and which we record in log files. Depending on how you interact with us, this log datamay include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searcches, and other actions you take suh as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to Access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browrser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type amd settings of the device you use to Access the Services. For example, we may use GPS and other Technologies to collect geolocation data that tell us your current location( based on your IP address). You can opt out of allowing us to collect this information either by refusinf Access to the information or by disabling your Location setting on yourdevice. However, if you choose to opt out, you may not able to use certain aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

To enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you, such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.

      2. HOW DO WE PROCESS YOUR INFORMATION ? 

• To facilitate account creation and authentication and oterwise manage user accounts: We may process your information so you can create and log in to your account, as well as keep your account in working order.

In Shorts : We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user: We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to user :  We may peocess your information to respond to your inquiries and solve any potential issues you might have with the requested services.
• To administrative information to you:  We may process your information to send you details about our products and services, changes to our terms and policies, and other similar informaiton.
• To fulfill and manage your orders : W emay process your infromation to fulfill and manage your orders, payments, returns, and exchanges madprocesse through the Services.
• To enable user-to-user communications :  We may process your information if you choose to use any of our offerings that allows for communication with another user.
• To request feedback :  We may process yoru infromationwhen necessary to request feedback and to contatc you about your use of our Services.
• To send you marketing and promotional communications :  We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more informaiton, see “WHAT ARE YOUR PRIVACY RIGHTS?” below.
• To deliver targeted advertising to you : We may process your information develop and displeay personalized content and advertising tailored to your interests, location, and more.
• To protect our Services : We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and preventation.
• To identify usage trends :  We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns :  We may process your informaiton to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual’s vital interest :  We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

     3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION ? 

In Shorts: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide  you with services to enter into or fulfill our contractual obligation, to protect your rights, or to fulfill our legitimate business interests.

Depending on the regions where you contact us, these legal bases may differ ; 

• If you are located in Turkey, this section applies to you. 
  • Consent: We may process yoru information if you have given us permission (i.e., consent) to use your personal information for a specific purposes. You can withdraw your consent at any time. For more informaiton, see “WHAT ARE YOUR PRIVACY RIGHTS” below.

The Personal Data Protection Law (PDPL) required us to explain the valid legal bases we rely on in order to process your information. As such, we may rely on the following legal bases to process your personel information. 

• Performance of Contract: We may process your personal informaiton when we believe it is necessary to fulfill our contractual obligaitons to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legimate business interests and those interests do not outweigh your interests and fundamental rights abd freedoms. For example, w emay process your personal information for some of the purposes described in order to:
  • Send users informaiton about special offers and discounts on our products and services.

• Develop and display personalized and relevant advertising content for our users
• Analyse how our Services are used so we can improve them to engage and retain users
• Support our marketing activities
• Diagnose problems and/or prevent fraudulent activities
• Understand how our users use our products and services so we can improve user experience

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligaitons, such as the cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your informaiton as evidence in litigaiton in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital insterests of a third party, such as situations involving potential threats to the safety of any person.

• If you are located in the EU or UK, this section applies to you.
  • Consent: We may process yoru information if you have given us permission (i.e., consent) to use your personal information for a specific purposes. You can withdraw your consent at any time. For more informaiton, see “WHAT ARE YOUR PRIVACY RIGHTS” below

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your informaiton. As such, w emay rely on the following legal bases to process your personal informaiton.

• Performance of Contract: We may process your personal informaiton when we believe it is necessary to fulfill our contractual obligaitons to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legimate business interests and those interests do not outweigh your interests and fundamental rights abd freedoms. For example, w emay process your personal information for some of the purposes described in order to:
  • Send users informaiton about special offers and discounts on our products and services.

• Develop and display personalized and relevant advertising content for our users
• Analyse how our Services are used so we can improve them to engage and retain users
• Support our marketing activities
• Diagnose problems and/or prevent fraudulent activities
• Understand how our users use our products and services so we can improve user experience

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligaitons, such as the cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your informaiton as evidence in litigaiton in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital insterests of a third party, such as situations involving potential threats to the safety of any person.

• If you are located in Canada, this Section applies to you.
  • If you collection is clearly in the interests of individual and consent cannot be obtained in a timely way.

We may process your information if you given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations whre your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. For more informaiton, see  “WHAT ARE YOUR PRIVACY RIGHTS” below

In some exceptioanl cases, we may be legally permitted under applicable law to process your informaiton without your consent, including,  for example:

• For investigatons and fraud detection and prevention.
• For business transactions provided certain conditions are met.
• If it is contained in awitness statement and the collection is necessary to assess, process, or settle an insurance.
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is or nmay be victim of financial abuse.
• If it is reasonable to expect collection and use with consent would compromise the availability or the accurancy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or contravention of the laws of Canada or a Province.
• If disclosure is required to comply with a subpoena warrant, court order, orrules of the court relating to the production of records.
• If it was produced by an individial in the course of their employment, business or profession and the collection is consistent with the purposes for which the infromation was produced..
• If the collection is solely for journalistic, artistic, or literary purposes.
• If the informaitonis publicly available and is specified by the regulaitons.

• If you are a resident of California, this Section applies to you.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal informaiton (if any) we disclosed to third parties for direct  marketing purposes and the names and addresses of all third parties with which we shared personal information in the imddediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

   2. 

• Every individual who is in the State of California for other than a temporary or transitory purposes and,

If youe are under 18 years of age and reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated  with  your account and a statement taht you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

• Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purposes

All other individuals are defined as “non-residents”.

If this defination of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past 12 (twelve) months:

We may also coolect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in delivery of our Services and to repond to your inquiries.

     4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION

In Shorts: We may share informaiton in specific situations described in this section and/or with the following parties.

We may need to share your personal information in the following situations:

• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of compant assets, financing, or acquisition of al lor a portion of our business to another company.

• When we use Google Maps Platfrom APIs: We may share your information with certain Google Maps Platform APIs (e.g., Google Maps APIs, Places API). To find out more about Google’s Privacy Policy. We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. A full list of what we use information for can be found in this section and in the previous section titled “ HOW DO WE PROCESS YOUR INFORMATION?”. We obtain and store on your device (“cache”) your location for twelve (12) months. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and Access cookies and other information on your devices. If you  are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway) or the United Kingdom, please take a look at our Cookie Policy.

• Company Affliates: We may share your information with our company affiliates, in which case we will require those affiliates to honor this policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  
   
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

      5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Shorts: We may use cookies and other tracking Technologies to collect and store your information.

We may use cookies and similar tarcking Technologies (like web beacons and pixels) to Access or store information. Specific information about how we use such Technologies and how you can refuse certain cookies is set out in our Cookies Policy.

    6. HOW WE HANDLE YOUR SOCIAL LOGINS ? 

In Shorts: If you choose to register or log in to our Services using a social media account, we may have Access to certain informaiton about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile Picture, as well as other informaitonyou choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information. By your third-party social media provider. We recommned that you reivew their privacy policy to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

    7. IS YOUR INFORMATION TRANSFFERED INTERNATIONALLY ? 

In Shorts: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Turkey. If you are accessing our Services from outside Turkey, please be aware that your informaiton may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see” WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION       ?“ above), in Turkey, and United States of America, Europe Zone and  other juristicditons. 

As an example, if you are resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy policy and applicanle law.

• European Commission’s Standard Contractual Clauses: We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses required all recipients to protect all personal information that theyprocess originating from the EEA and UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and futher details can be provide upon request.

     8. HOW LONG DO WE KEEP YOUR INFORMATION ? 

In Shorts: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise requires by law.

We will keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law ( such as tax, accounting, or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

   2. 

We have nı ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

     9. HOW DO WE KEEP YOUR INFORMATION SAFE ?

In Shorts: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be %100 secure,  so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and imporperly collect, access, steal, or modify yoru information. Although we will do our best to protect your personal information tarnsmission of personal infromation to and from our Services is at your own risk. You should only access the Services with a secure environment.

   10. WHAT IS YOUR PRIVACY RIGHTS ? 

In Shorts: In some region, such as European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that alow you greater Access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request Access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processinfg of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have right to object to the processing of your personal information. You can make such a request by contacting us by using the contact detaşls provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: 

https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

If youe are located in Switzerland, the sontact details fort eh data protection authorities are available here: 

https://www.edoeb.admin.ch/edoeb/en/home.html

Withdrawing your consent: 

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?”  belowor updating your preferences. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications:

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubcribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below. You will then be removed from the marketing lists. However, we may still communşcate with yot- for example, to send you service-related messages that are necessary for the administration and use ıf your account, to respond to service requests, or for other non-marketing purposes.

Account Information : 

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact us using contact information provided.
• Log in to your account settings and update your users account.
  
   

Upon your requets to terminate your account, we will deactive or delete your account and information from our active databases. However, w emay retain some information in our files to prevent fraud, troubleshoot problems, assit with any investigation, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies:

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/

 

If you have any questions or commnets about your privacy rights, you may emial us at [email protected].

    
      11. CONTROLS FOR DO – NOT – TRACK FEATURES 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not have data about you online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that authomatically communicates your choice not be tracked online. If a standard for onlinetracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this 

    12.  DO WE MAKE UPDATES TO THİS NOTICE ?

In Shorts: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

   13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE ? 

If you have questions or comments about this policy, you may contact our Data Protection Officer, by email at [email protected], or by post to:

Karadere Turizm Organizayon Limited Sirketi 

Saray Mah. Dr. Adnan Büyükdeniz Cad. No:4/18 Cessas Plaza, 34768, Ümraniye/İstanbul 

     14. HOW CAN YOU REVISE, UPATE OR DELETE THE DATA WE COLLECT FROM YOU ? 

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update or delete your personal information, please send an e-mail to [email protected]