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PDPL

ARİNNA SWİMWEAR

PRIVACY NOTICE UNDER THE PERSONAL DATA PROTECTION LAW

Prepared under Law No. 6698 on the Protection of Personal Data | Last updated: 01.06.2026


Last Updated 01.06.2026
Website www.arinnaswimwear.com
E-mail arinna@arinnaswimwear.com


1. Identity of the Data Controller

Pursuant to Law No. 6698 on the Protection of Personal Data (the “KVKK”), the data controller in respect of your personal data is ARİNNA GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ (“Arinna Swimwear”, the “Company” or the “Seller”).

Information Description
Trade Name ARİNNA GİYİM SANAYİ VE TİCARET LİMİTED ŞİRKETİ
Address Adnan Kahveci Mah. Yavuz Sultan Selim Blv. Perla Vista Sitesi No: 1B İç Kapı No: 16 Beylikdüzü / İSTANBUL
Tax Office / Tax No. Büyükçekmece Tax Office / 0790893546
MERSIS No. 0406243553460001
Trade Registry No. 1083599
Telephone / Customer Service +90 533 917 15 29
E-mail arinna@arinnaswimwear.com
Website www.arinnaswimwear.com
Contact / Application Address arinna@arinnaswimwear.com


2. Scope of the Privacy Notice

This Privacy Notice has been prepared in order to provide information about the purposes for which, the legal bases on which, and the methods by which personal data is processed, and the parties to whom it may be transferred, in respect of: persons who visit the website at www.arinnaswimwear.com; customers who place orders as members or without membership; prospective customers; recipients of commercial electronic messages; persons who contact customer service; persons who file withdrawal/return/defective-product applications; and delivery recipients whose information is shared in connection with an order.

The Company processes your personal data in a manner that is lawful and fair, accurate and, where necessary, up to date, for specified, explicit and legitimate purposes, and in a manner that is connected, limited and proportionate to those purposes; it retains the data for the period prescribed under the relevant legislation or for as long as necessary for the purpose of processing.


3. Methods of Collecting Personal Data

Your personal data may be collected through the following channels by automated, partially automated, or non-automated means, provided that the data forms part of a data filing system:

  • Website membership, cart, order, payment, delivery, invoice, contact, request/complaint, withdrawal, return and defective-product application fields;
  • Communication channels such as e-mail, telephone, WhatsApp, social media messages and customer service;
  • Service providers such as payment institutions, banks, courier/logistics companies, e- invoice/e-archive providers, the e-commerce infrastructure, hosting, security, customer support, e-mail/SMS and similar providers;
  • Cookies, pixel/tag technologies, server logs, IP records, device/session information and electronic consent records;
  • Notifications transmitted, as required by legislation, by competent public authorities and institutions, judicial bodies or competent authorities.


4. Categories of Personal Data Processed

Category Example Data
Identity Information Name, surname; where required for a corporate invoice or by legislation, title, tax identification number, tax office and limited invoicing information.
Contact Information E-mail address, telephone number, delivery address, invoice address, customer service communication records.
Customer Transaction Information Membership/order information, order number, product name/model/colour/size, cart information, order history, delivery and courier records, return/withdrawal/exchange/defective-product application records, transaction dates, consent records.
Finance and Payment Transaction Information Payment method, transaction reference number, instalment information, refund records, bank/payment-institution transaction result. Credit card and debit card details are not stored in the Company’s systems; they are processed through the payment institution/bank infrastructure.
Transaction Security Information IP address, device and browser information, session records, log records, date-time information, security verification records, indicators of misuse and suspicious transactions, contract/form/notice/consent version records.
Marketing Information Commercial electronic message consent/opt-out records, newsletter preferences, campaign and communication interactions, marketing cookie preferences, product interests and shopping preferences.
Request, Complaint and Legal Process Information Content of requests/complaints, withdrawal and return requests, defective- product examination applications, dispute correspondence, evidentiary records, legal application and response records.
Visual/Audio Records Product photographs/video recordings and packaging/courier images submitted by the customer in connection with a defective-product or examination application. The Company does not request special categories of personal data; special-category content not necessary for product examination must not be processed, and if submitted, parts not necessary for assessing the request may be deleted, masked, or a re-application may be requested.
Cookie and Digital Tracking Information Cookie identifiers, session and preference information, site usage activity, page views, source/channel information, analytics and advertising/marketing preferences. Details are explained in the Cookie Policy.


5. Purposes and Legal Bases of Processing Personal Data

Your personal data is processed for the following processes and purposes, relying on the legal bases set out in Article 5 of the KVKK and the relevant legislation:

Process Related Data Categories Purpose Legal Basis
Membership and customer account operations Identity, contact, customer transaction, transaction security Creating membership, managing the user account, accessing order history, account security and customer verification. KVKK Art. 5(2)(c): conclusion/performance of a contract; Art. 5(2)(f): legitimate interest; Art. 5(2)(e): establishment/exercise/pr otection of a right.
Order, sale and distance contract processes Identity, contact, customer transaction, payment transaction, transaction security Receiving the order, carrying out the Distance Sales Contract and Pre-Information Form processes, effecting the sale and delivery of products, keeping electronic consent records. KVKK Art. 5(2)(c); Art. 5(2)(e).
Payment and refund operations Finance/payment transaction, customer transaction, transaction security Receiving payment, payment security, control of suspicious/fraudulent transactions, refunds and financial reconciliation. KVKK Art. 5(2)(c); Art. 5(2)(ç): legal obligation; Art. 5(2)(f); Art. 5(2)(e).
Invoicing, e- archive/e-invoice, accounting and tax operations Identity, contact, invoice, finance, customer transaction Issuing invoices, keeping accounting records, fulfilling obligations arising from tax, commercial and consumer legislation. KVKK Art. 5(2)(ç); Art. 5(2)(e).
Courier, delivery and delivery- recipient processes Identity, contact, delivery address, customer transaction, courier records Dispatching the product to the specified address, delivery tracking, resolving delivery issues, managing return/examination shipments. KVKK Art. 5(2)(c); Art. 5(2)(e); Art. 5(2)(f).
Withdrawal, return, defective-product and examination processes Identity, contact, customer transaction, request/complaint, visual records, courier records Right of withdrawal, return, defective-product examination, hygiene-suitability and resale- suitability checks, assessment of consumer requests. KVKK Art. 5(2)(c); Art. 5(2)(ç); Art. 5(2)(e); Art. 5(2)(f).
Customer service, request and complaint management Identity, contact, customer transaction, request/complaint, transaction security Answering questions, providing support, finalising requests, ensuring customer satisfaction. KVKK Art. 5(2)(c); Art. 5(2)(e); Art. 5(2)(f).
Website security and prevention of misuse Transaction security, IP/log, device/session, cookie information Ensuring information security and preventing risks of fake accounts, suspicious transactions, technical misuse, campaign/coupon misuse and fraud. KVKK Art. 5(2)(f); Art. 5(2)(e); Art. 5(2)(ç).
Legal obligations, evidence and dispute management Identity, contact, customer transaction, finance, request/complaint, electronic records Fulfilling retention, notification and evidentiary obligations arising from legislation; resolving disputes; providing information to competent authorities, bodies and courts. KVKK Art. 5(2)(ç); Art. 5(2)(e).
Commercial Contact, marketing, Where separate and explicit KVKK Art. 5(1): explicit
electronic message and marketing processes consent/opt-out records, campaign interactions consent exists, sending campaigns, discounts, announcements, promotions and newsletters; managing commercial electronic message consent/opt-out processes. consent; additional consent under the relevant commercial electronic message legislation. Not mandatory for the provision of products/services.
Cookies and digital tracking Cookie and digital tracking information, transaction security, usage information Operation of the site via strictly necessary cookies; site experience, measurement and marketing activities via permitted analytics, performance, functionality, advertising and marketing cookies. For strictly necessary cookies, KVKK Art. 5(2)(c) or 5(2)(f); for non- essential cookies, explicit consent under KVKK Art. 5(1).


6. Transfer of Personal Data

Your personal data may be shared, in a manner limited and proportionate to the processing purposes and in accordance with Articles 8 and 9 of the KVKK and the relevant legislation, with the following groups of recipients:

Recipient Group Purpose of Transfer
Courier and logistics companies Delivery of the product, return/examination shipment, courier tracking and resolution of delivery issues.
Banks and payment institutions Receiving payment, payment security, instalments, refunds, financial reconciliation and control of suspicious transactions. Card details are not stored in the Company’s systems.
E-commerce infrastructure, software, hosting, cloud, security and technical service providers Operating the website, the membership/order infrastructure, data hosting, security, backup, logging, technical support and system management.
E-invoice/e-archive providers, accounting, financial advisory, finance, audit and reporting service providers Invoicing, accounting, tax, financial reporting and fulfilment of legal obligations.
Customer support, e-mail, SMS, communication, CRM and commercial electronic message service providers Request/complaint management, informational messages, permitted commercial electronic messaging, management of consent/opt-out and record processes.
Advertising, analytics, cookie and marketing technology providers Where explicit consent/cookie preference exists, advertising, retargeting, measurement, performance analysis and campaign management.
Law firms, advisors, auditors and insurance/dispute-resolution parties Establishment, exercise and protection of legal rights; dispute and audit processes.
Competent public authorities and institutions, judicial bodies and enforcement offices Fulfilment of legal obligations and responding to official requests.
Suppliers and business partners Limited sharing necessary to carry out order, stock, operations, product supply, campaign and after-sales processes.


7. Transfers Abroad

As a rule, the Company processes your personal data to the extent required by its activities and service processes. However, where the technical infrastructure of e-commerce, hosting, cloud, e- mail, customer communication, analytics, advertising/marketing, cookie, security or payment services is located abroad, or where the service provider is established abroad, your personal data may be transferred abroad.

Such transfer is carried out only if one of the following exists: an adequacy decision, appropriate safeguards, or one of the exceptional transfer circumstances regulated under the relevant legislation, as set out in Article 9 of the KVKK, and provided that the necessary technical and administrative measures are taken. Detailed information regarding service providers and cookies that require transfers abroad may also be provided through the relevant service/cookie screens and the Cookie Policy.


8. Commercial Electronic Messages and Marketing

Commercial electronic messages with marketing content, such as campaigns, discounts, promotions, announcements and newsletters, are sent only where separate consent/explicit consent has been obtained. Such consent is not mandatory for purchasing a product or service and is not a precondition for completing an order.

You may withdraw your commercial electronic message consent at any time. Once your opt- out/cancellation request is processed, the sending of marketing messages is stopped; however, consent/opt-out and transaction records may be retained for the periods prescribed by legislation for the purposes of fulfilling legal obligations and providing evidence.


9. Cookies and Digital Tracking Technologies

Cookies that are strictly necessary for the operation of the website may be used, without requiring explicit consent, on the basis of the relevant legal grounds. Non-essential cookies used for analytics, performance, functionality, advertising, retargeting and marketing purposes are, as a rule, subject to your explicit consent.

Detailed information about the types of cookies, their providers, purposes of use, retention periods, whether they are first- or third-party, and how you can manage your preferences is provided in the Cookie Policy and the cookie preference panel. Merely accessing the website does not mean that you have given explicit consent to non-essential cookies.


10. Third-Party Information and Special-Category Data Warning

If you request that an order be delivered to another person, the name-surname, telephone and address information of the delivery recipient is processed solely for the purpose of effecting delivery and carrying out delivery-related processes. When sharing information belonging to third parties, you are advised to inform such persons to the extent necessary.

The Company does not request special categories of personal data. If a photograph/video must be shared to demonstrate a product defect in return, defective-product or examination applications, care must be taken to ensure that the images do not contain health data, biometric data, nudity, intimate areas, images of children, or any other personal data not necessary for product examination.


11. Retention Period of Personal Data

Your personal data is retained for as long as required by the purposes of processing, taking into account the retention periods prescribed under the relevant legislation, statutes of limitation, obligations arising from accounting/tax/commercial/consumer legislation, and the periods necessary for the resolution of disputes. When the purpose and legal basis cease to exist, personal data is deleted, destroyed or anonymised in accordance with the legislation.

Data / Record Type Retention Approach
Order, contract, pre-information, electronic consent and delivery records For the necessary period, taking into account consumer legislation, the contractual relationship and dispute limitation periods.
Invoice, accounting, e-archive/e-invoice, payment and finance records For the relevant statutory retention periods, primarily under tax and commercial legislation; in practice, retention of up to 10 years may apply for commercial books and records.
Withdrawal, return, defective-product, complaint and customer service records For the period necessary to finalise the request and for evidentiary and dispute processes.
Commercial electronic message consent/opt-out records Until consent is withdrawn; opt-out/consent and evidentiary records for the period necessary for legal obligations and evidentiary purposes.
Cookie, log and transaction security records For the periods stated in the Cookie Policy and reasonable periods necessary for information security/dispute processes.


12. Rights of the Data Subject

Pursuant to Article 11 of the KVKK, you have the following rights in respect of your personal data:

  1. to learn whether your personal data is being processed;
  2. to request information if your personal data has been processed;
  3. to learn the purpose of processing and whether the data is used in accordance with such purpose;
  4. to know the third parties to whom your personal data is transferred domestically or abroad;
  5. to request rectification of incompletely or inaccurately processed personal data;
  6. to request the erasure or destruction of your personal data under Article 7 of the KVKK;
  7. to request that rectification, erasure or destruction operations be notified to third parties to whom the data has been transferred;
  8. to object to any adverse outcome arising against you as a result of the processed data being analysed exclusively by automated systems;
  9. to claim compensation for damage suffered due to the unlawful processing of personal data.


13. Method of Application

You may submit your requests under the KVKK to the Company by the following methods, including the information necessary to substantiate your identity and your request:

  • Written application: by a wet-signed petition sent to the Company’s address;
  • E-mail: to arinna@arinnaswimwear.com using your e-mail address registered in the Company’s systems;
  • By methods prescribed by legislation such as secure electronic signature, mobile signature or registered electronic mail (KEP); if the Company has separately announced a KEP address, to that address;
  • Through an application form or application field, if provided on the website.

Applications are finalised within 30 days at the latest. Depending on the nature of the request, additional information or documents may be requested to verify that the application belongs to you. Applications are, as a rule, free of charge; however, if the operation requires an additional cost, the fees prescribed by legislation may be charged.


14. Updates

This Privacy Notice may be updated in line with changes in legislation, decisions of the Board, business processes, technical infrastructure, the service providers used, cookies or data processing activities. The current text becomes effective as of the date it is published at www.arinnaswimwear.com.

Last Updated: 01.06.2026
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