1. Data Controller
Data Controller / Operator: Aydın Okan Polat
Platform: CLEWASE
Address: Mevlana Mah. Sayer Cad. Kalender Apt. No:35/30 Talas / Kayseri, Türkiye
Telephone: +90 541 124 38 50
Email: info@clewase.com
Website: clewase.com
2. Personal Data We May Collect
Depending on how you use CLEWASE, we may process the following categories of personal data:
- Identity information such as first name and last name
- Contact information such as email address, phone number and postal address
- Account and authentication information
- Order, product, cart, billing and delivery information
- Seller store and marketplace connection information
- Customer information submitted by sellers for fulfillment
- Uploaded designs, artwork, files and personalization details
- Transaction and payment-related information received from payment service providers
- Communications, support requests and complaint records
- IP address, browser, device, operating system and technical logs
- Cookie, session, security and fraud-prevention information
3. Purposes of Processing
Personal data may be processed for the following purposes:
- Creating, authenticating and managing user and seller accounts
- Displaying and managing products, carts and orders
- Processing checkout and coordinating payment transactions
- Producing, personalizing, fulfilling and shipping orders
- Connecting and synchronizing supported sales channels where requested
- Providing customer and seller support
- Managing cancellations, returns, refunds and disputes
- Preventing fraud, abuse and unauthorized access
- Operating, securing and improving CLEWASE
- Sending transactional, account, security and service communications
- Complying with legal, accounting, tax, consumer protection and regulatory obligations
- Establishing, exercising or defending legal rights
4. Legal Grounds
Where Turkish personal data protection law applies, personal data may be processed on one or more legal grounds permitted by applicable law, including where processing is necessary for the establishment or performance of a contract, compliance with a legal obligation, establishment, exercise or protection of a right, or where processing is necessary for the legitimate interests of the data controller provided that the fundamental rights and freedoms of the data subject are not harmed.
Where applicable law requires explicit consent for a particular processing activity, such processing will be carried out on the basis of the consent obtained.
5. Method of Collection
Personal data may be collected electronically through clewase.com, account registration forms, checkout forms, seller dashboards, connected marketplace integrations, uploaded files, cookies, security technologies, email, support communications and information transmitted by service providers involved in payment, production, fulfillment or delivery.
Data may also be generated automatically through technical logs and security records when you use the platform.
6. Account and Authentication Data
When you create a CLEWASE account, we process information necessary to create, authenticate, secure and maintain the account.
Passwords are handled through our authentication infrastructure and are not intended to be stored by CLEWASE in readable form.
7. Order and Fulfillment Data
When an order is created, CLEWASE may process product selections, quantities, designs, personalization information, recipient names, delivery addresses, phone numbers and other information necessary to prepare and deliver the order.
Where sellers submit customer information for fulfillment, the seller is responsible for ensuring that the information has been collected and transmitted lawfully.
8. Payment Information
Payment transactions may be processed by authorized third-party payment service providers. CLEWASE may receive transaction identifiers, payment status, amount, currency and limited payment-related information necessary to manage the order.
Full payment card details should be processed directly by the applicable payment provider where the payment infrastructure is configured accordingly.
9. Uploaded Designs and Content
Designs, artwork, images, text and other files uploaded to CLEWASE may be processed and stored as necessary to provide product preparation, production, order and fulfillment services.
Uploaded content may be transmitted to production or fulfillment providers only to the extent reasonably necessary to complete the requested service or as otherwise permitted by law.
10. Cookies and Similar Technologies
CLEWASE may use cookies, local storage and similar technologies for essential functions such as authentication, cart operation, security and preference storage.
Non-essential cookies or analytics technologies will be handled in accordance with applicable consent requirements where required.
11. Recipients and Transfers
Personal data may be transferred, where necessary and permitted by law, to service-provider categories such as payment institutions, banks, authentication providers, hosting and infrastructure providers, email providers, manufacturers, print providers, fulfillment partners, shipping carriers, marketplace integration providers, professional advisers and legally authorized public authorities.
Transfers are limited to the purposes for which the relevant service is provided or where disclosure is required or permitted by law.
12. International Data Transfers
Some technology, production, marketplace, fulfillment or infrastructure providers used by CLEWASE may operate outside Türkiye. Personal data may therefore be transferred abroad where the conditions and safeguards required by applicable data protection law are satisfied.
Where required, CLEWASE will rely on an applicable legal transfer mechanism or other safeguard permitted under the relevant law.
13. Data Retention
Personal data is retained only for as long as necessary for the purpose for which it was processed and for applicable legal, accounting, tax, consumer, security, fraud-prevention and dispute-resolution periods.
When the applicable retention purpose and legal period end, data is deleted, destroyed or anonymized in accordance with applicable law and operational requirements.
14. Data Security
CLEWASE uses reasonable technical and organizational safeguards designed to protect personal data against unauthorized access, alteration, disclosure, loss and misuse.
No electronic system can provide an absolute guarantee of security, but security measures are reviewed and improved where reasonably appropriate.
15. Rights of Data Subjects
Where Law No. 6698 applies, data subjects may exercise the rights provided under Article 11 of that law, subject to applicable conditions and exceptions.
- Learn whether personal data is being processed
- Request information if personal data has been processed
- Learn the purpose of processing and whether data is used in accordance with that purpose
- Know the third parties to whom personal data is transferred domestically or abroad
- Request correction of incomplete or inaccurate personal data
- Request deletion or destruction where the legal conditions are met
- Request notification of correction, deletion or destruction to third parties where applicable
- Object to a result arising against the person exclusively through automated processing where the statutory conditions apply
- Request compensation where damage is suffered due to unlawful processing
16. Exercising Your Rights
Requests concerning personal data may be submitted to CLEWASE using the contact information below. The request should include sufficient information to identify the applicant and clearly describe the requested action.
Requests under Law No. 6698 are reviewed as soon as possible and, where Article 13 applies, no later than 30 days, subject to the applicable statutory procedure and permitted fees.
CLEWASE may request additional information where reasonably necessary to verify the identity of the applicant and protect personal data from unauthorized disclosure.
17. Account Deletion
Users may contact CLEWASE to request account deletion.
Deletion of an account does not necessarily require immediate deletion of every record where retention is required by law or remains necessary for orders, accounting, security, fraud prevention, legal claims or dispute resolution.
18. Children
CLEWASE is intended for persons legally capable of entering into the relevant transactions and is not designed as a service directed specifically to children.
19. Changes to This Policy
This Privacy Policy may be updated when our services, processing activities or legal obligations change. The current version will be published on this page with the revised update date.
20. Contact
Data Controller / Operator: Aydın Okan Polat
Platform: CLEWASE
Address: Mevlana Mah. Sayer Cad. Kalender Apt. No:35/30 Talas / Kayseri, Türkiye
Telephone: +90 541 124 38 50
Email: info@clewase.com
