PRIVACY POLICY - TUMBAKI HOOKAH TOBACCO

INTRODUCTION

Tumbaki (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. Tumbaki Tobacco Tütün Mam. San. Tic. Ltd. Şti. is the controller and responsible for your data. Tumbaki is a legal entity. When we mention “Company”, we are referring to the company in the Tumbaki responsible for processing your data which will be clear to you when you use our website. Tumbaki Tobacco Tütün Mam. San. Tic. Ltd. Şti. is the controller responsible for this website.

This policy describes the information we may collect from you or that you may provide when you visit the website http://www.tumbaki.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

On this Website.
In email, text, and other electronic messages between you and this Website.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

us offline or through any other means, including on any other website operated by Company or any third party; or
any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change occasionally. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

ADULT AUDIENCE

The Website is intended only for use by adults of legal age to purchase tobacco products in your jurisdiction or residence (at least 18 years of age and over in most Countries and at least 21 in most states of some countries). No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at: [email protected]

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

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

by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
that is about you but individually does not identify you; and/or
about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
From third parties, for example, our business partners.

Information You Provide to Us. The information we collect on or through our Website may include:

information you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research.
Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please know that no security measures are perfect or impenetrable. We cannot control the actions of other users of the Website with whom you may share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your interests.
Speed up your searches.
Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you we collect from other sources or you provide to us.

THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website are served by third-parties, including content providers and application providers. These third parties may use cookies alone or with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have questions about an advertisement or other targeted content, contact the responsible provider directly. For information about how you can opt-out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

HOW WE USE YOUR INFORMATION

We use the information we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To provide you with the information you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account, including expiration and renewal notices.
To comply with regulatory obligations, such as (where appropriate) verifying your age.
To notify you about changes to our Website.
To allow you to participate in interactive features on our Website.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users without restriction.

We may disclose personal information we collect, or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor if a merger occurs, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Website users is among the assets transferred.
To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use or any other agreements.
If disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of this site may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the box on the form on which we collect your data (the registration/contact form). You can also always opt-out by sending us an email stating your request to [email protected]
Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the box on the form on which we collect your data (the registration form) or at any other time by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to the Company because of a product purchase, warranty registration, product service experience, or other transactions.
Targeted Advertising. If you do not want us to use the information we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected] do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

ACCESSING AND CORRECTING YOUR INFORMATION

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at [email protected] to request access to, correct, or delete any personal information you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use.

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

YOUR EU DATA SUBJECT RIGHTS

EU individuals have the following rights (when acting as a processor, individuals must exercise these rights with the data controller):

Access, Rectification, Portability, and Deletion. You have the right to access your personal information held by us. You may do so by sending an email to [email protected]. Besides, you may also have the right to request that certain personal information be exported to another provider where technically feasible, and under certain conditions to object to or restrict our use of certain personal information.
Withdraw Consent. Where we process your personal information based on your consent, you have the right to withdraw your consent without affecting the lawfulness of processing based on consent before its withdrawal.
Object to Processing. You have the right to object to processing (including profiling) based on legitimate interest grounds, where we are relying upon legitimate interests to process personal information. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or we need to process the personal data for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case individually.
Object to Marketing. You have the right to object to our use of your personal information (including profiling) for direct marketing, such as when we use your data to invite you to our promotional events.
Right to Lodge a Complaint. You may complain with a supervisory authority. Any requests about your rights should be directed to [email protected]. Certain services will not be available if you withdraw your consent, or otherwise delete or object to our processing of certain personal information. We will respond to your request under applicable law, and we will inform you if we do not intend to comply with your request.

INTERNATIONAL USERS

If you live in the European Economic Area (“EEA”) or Canada, the data we collect from you may be transferred to, or accessed in, and stored at a location outside the EEA and Canada that may not provide equivalent levels of data protection as your home jurisdiction. When the Company stores personal data outside the EEU, the data will be stored in the United States. We will take steps to ensure that your data receives an adequate level of protection in the jurisdictions in which we process it. It may also be processed by staff operating outside the EEA and Canada who work for us or one of our service providers. Such staff may process and store your information and provide support services. By submitting your personal information, you agree to this transfer, storing or processing. We will ensure that your personal information is treated securely and under this privacy policy.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures on the Website.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION

To ask questions about this privacy policy and our privacy practices, contact us at: [email protected].