Digital Closet Privacy Policy

Introduction

At Digital Closet ("Application", "we", "us", "our"), we value your privacy and are committed to protecting your personal data. This Privacy Policy is designed to help you understand how we collect, use, disclose, and safeguard your personal information when you use our mobile application.

By accessing or using the Application, you acknowledge that you have read, understood, and agree to be bound by the terms of this Privacy Policy. If you do not agree with our practices, please do not use our Application.

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We encourage you to review this Privacy Policy periodically to stay informed about our information practices.

Data Controller

Digital Closet is the data controller responsible for the processing of personal data described in this Privacy Policy. If you have any questions, concerns, or requests regarding your personal data or this Privacy Policy, please contact us using the information provided at the end of this document.

Data Controller Information:

Company Name: Digital Closet
Registered Address: 123 Fashion Avenue, Istanbul, Turkey
Email: privacy@digitalcloset.com
Phone: +90 (212) 555-1234

Information We Collect

We collect several types of information from and about users of our Application, including:

• Account Information: When you register for an account, we collect your name, email address, username, and password. This information is necessary to create and maintain your account and to provide you with our services.
• Profile Information: We collect information that you provide in your profile, such as your profile picture, gender preferences, body measurements, style preferences, and personal description. This information helps us personalize your experience and provide more relevant clothing recommendations.
• Clothing Data: We collect the clothing photos you upload to the Application, as well as any information you provide about these items (e.g., brand, color, size, category, purchase date, price, and wear frequency). This information is central to the core functionality of our Application.
• Device Information: We automatically collect technical information about the devices you use to access our Application, including device type, hardware model, operating system, unique device identifiers, IP address, mobile network information, and crash reports. This information helps us provide and improve the Application's functionality.
• Usage Data: We collect information about how you interact with our Application, including the features you use, the pages you visit, the time and duration of your sessions, and other actions you take within the Application. This helps us understand how users engage with our Application and identify areas for improvement.
• Location Information: With your consent, we may collect precise or approximate location information from your device to provide location-based services, such as weather-appropriate outfit recommendations. You can revoke this consent at any time through your device settings.
• Communications: If you contact us directly, we may collect and store the communications, including any personal information you include in those communications.

Methods of Data Collection

We collect data through various methods:

• Direct Interactions: Information you provide when creating or updating your account, setting up your profile, uploading clothing items, or communicating with us.
• Automated Technologies: As you navigate through and interact with our Application, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns.
• Third-Party Sources: If you choose to log in to our Application using your social media account (e.g., Facebook, Google, or Apple), we may collect certain information from that platform in accordance with the authorization procedures determined by these third-party services.
• Analytics Tools: We use analytics tools to help us measure traffic and usage trends. These tools collect information about how you use our Application, which helps us improve our services and your experience.

Purposes of Data Use

We use the information we collect for various purposes, including:

• Provide and Maintain the Application: To create and manage your user account, deliver the core features of the Application, and process your transactions.
• Personalization: To personalize your experience by providing tailored content, such as clothing recommendations based on your preferences, style, and past behavior.
• Improvement and Development: To analyze usage patterns, conduct research, and gather demographic information to understand and improve our Application's features and services.
• Communication: To communicate with you regarding your account, updates to our Application, technical notices, security alerts, and administrative messages.
• Marketing: With your consent, to send promotional communications, such as offers, promotions, and information about new features or products. You can opt out of these communications at any time.
• Security and Fraud Prevention: To monitor and analyze usage and activity trends to detect, prevent, and address technical issues, fraud, abuse, and illegal activities.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
• Enforcement of Rights: To enforce our Terms of Use and other legal agreements, and to protect the rights, property, or safety of Digital Closet, our users, or others.

Legal Basis for Processing

We process your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and us (i.e., to provide you with the services of our Application as outlined in our Terms of Use).
• Legitimate Interests: Processing is necessary for our legitimate interests, such as to improve our Application, prevent fraud, market our services, or conduct data analytics, provided these interests are not overridden by your rights and freedoms.
• Consent: Where we rely on your consent for certain processing activities, such as sending marketing communications or collecting location data. You have the right to withdraw your consent at any time.
• Legal Obligation: Processing is necessary to comply with a legal obligation to which we are subject.

Data Sharing and Disclosures

We may share your personal information with the following categories of recipients:

• Service Providers: We may share your information with third-party vendors, service providers, contractors, or agents who perform functions on our behalf, such as data storage, server hosting, analytics, and payment processing. These entities are contractually bound to use personal data only as necessary to provide their services to us.
• Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Application of any change in ownership or uses of your personal information.
• Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
• Protection of Rights: We may disclose your information when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• With Your Consent: We may share your information with third parties when you have given us your consent to do so.

We take all necessary steps to ensure that third-party service providers process your personal data in accordance with this Privacy Policy and applicable data protection laws, and that they implement appropriate technical and organizational measures to protect your data.

International Data Transfers

Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country.

Specifically, our Application servers are located in the European Union, and our third-party service providers and partners operate around the world. This means that when we collect your personal data, we may process it in any of these countries.

However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Privacy Policy. When we transfer your personal data outside of the European Economic Area (EEA), we ensure that a similar degree of protection is afforded to it by implementing appropriate safeguards, including the use of standard contractual clauses approved by the European Commission.

Data Security

We have implemented appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include:

• Encryption: We use industry-standard encryption technologies to protect your data in transit and at rest, including Secure Socket Layer (SSL) technology.
• Access Controls: We restrict access to personal data to employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Application. These individuals are bound by confidentiality obligations.
• Security Protocols: We follow industry best practices for securing our infrastructure and systems, including regular security assessments, vulnerability management, and penetration testing.
• Data Backup: We regularly back up our systems to minimize the risk of data loss in the event of a system failure.
• Incident Response: We have developed procedures to handle data breaches, including notification protocols in accordance with applicable laws.

However, despite our efforts, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. You are responsible for maintaining the secrecy of your unique password and account information.

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider:

• The amount, nature, and sensitivity of the personal data
• The potential risk of harm from unauthorized use or disclosure of your personal data
• The purposes for which we process your personal data
• Whether we can achieve those purposes through other means
• The applicable legal requirements

In general, we will retain your personal data for the duration of your relationship with us (i.e., as long as you have an active account). When you delete your account, we will generally delete your personal data within 30 days. However, we may retain certain information as required by law or for legitimate business purposes, such as:

• Information needed for tax or financial record-keeping purposes
• Information needed to defend or pursue legal claims within the applicable statutes of limitations
• Aggregated, de-identified data that cannot be used to identify you

Children's Privacy

Our Application is not intended for children under the age of 16, and we do not knowingly collect personal data from children under 16. If we learn that we have collected personal data from a child under 16, we will take steps to delete that information as quickly as possible.

If you believe that we may have collected personal data from a child under 16, please contact us using the information provided at the end of this Privacy Policy.

Your Rights

Depending on your jurisdiction, you may have certain rights regarding your personal data. These may include:

• Right to Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You have the right to request that we delete your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when the accuracy of the data is contested.
• Right to Data Portability: You have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format, and to have this data transmitted to another data controller.
• Right to Object: You have the right to object to the processing of your personal data in certain circumstances, such as for direct marketing purposes or when processing is based on our legitimate interests.
• Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the information provided at the end of this Privacy Policy. We will respond to your request within one month, but we may extend this period by up to two additional months if necessary, taking into account the complexity and number of requests.

Please note that we may need to verify your identity before responding to your request. In some cases, we may also need to retain certain personal data where we have a legal obligation or legitimate interest to do so.

Cookies and Tracking Technologies

Our Application may use cookies, beacons, tags, scripts, and similar tracking technologies to collect information about your browsing activities. Cookies are small data files stored on your device that help us improve our Application and your experience, see which areas and features of our Application are popular, and count visits.

We use the following types of cookies:

• Essential Cookies: These cookies are necessary for the Application to function and cannot be switched off in our systems. They are usually only set in response to actions you take, such as logging in or filling in forms.
• Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Application. They help us to know which pages are the most and least popular and see how visitors move around the Application.
• Functionality Cookies: These cookies enable the Application to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our Application.
• Targeting Cookies: These cookies may be set through our Application by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites.

You can control the use of cookies at the individual browser level. However, if you choose to disable cookies, this may limit your use of certain features or functions of our Application.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. You can see when this Privacy Policy was last updated by checking the "Last updated" date displayed at the top of this Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about our information practices and your privacy rights and choices.

Right to Complain

If you have any concerns about our use of your personal data, you have the right to lodge a complaint with your local data protection authority. However, we would appreciate the chance to deal with your concerns before you approach your data protection authority, so please contact us in the first instance.

In Turkey, the data protection authority is the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu). You can find more information about how to contact them on their website:https://www.kvkk.gov.tr/.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Digital Closet
123 Fashion Avenue
Istanbul, Turkey
Email: privacy@digitalcloset.com
Phone: +90 (212) 555-1234

We will respond to your request within a reasonable timeframe and in accordance with applicable data protection laws.