DUEPLE PRIVACY POLICY


DUEPLE respects your privacy and is committed to protect the personal information that you share with us. Generally, you can browse through our website without giving us any information about yourself (except for cookies and pixel tags, as provided in our Cookie Policy [Note: insert link]). When we do need your personal information to provide services that you request or when you choose to provide us with your personal information, for example when you decide to purchase an item, contact us for additional information or subscribe to our newsletter, this policy describes how we collect and use your personal information.


Who is Responsible for the Processing of Your Personal Data?

The entity responsible for the processing of your personal data is ALPIN CORAP SANAYI VE TICARET A.S. [Please confirm or replace with the UK entity], referred to as “DUEPLE”, “our”, “we” or “us” in this privacy policy.


How We Collect and Use Information

Personal information means any information that may be used to identify an individual, including, but not limited to, a first and last name, email address, a home, postal or other physical address, other contact information, title, birth date, gender, occupation, industry, personal interests, other information when needed to provide a product or service you requested.

Information for Processing Your Purchases

We collect and store personal information such as name, address, email address, telephone number, previous purchases, health information (only if you purchase the Dueple Swiit products and only for the potential presumption that you are interested in socks for diabetics) and other contact information, for the purpose of processing your purchases and delivering the items you ordered to you, for example, arranging for shipping and handling, processing your payment details and managing your returns.

Information for Customer Support and Inquiries

We collect and store personal information, such as name, address, email address, telephone number,  purchase history and contact information [please confirm and complete], when you submit inquiries or requests with respect to our products, or when you contact us for the purpose of purchasing products. We will use such information to contact you only for the purposes for which you sent the inquiry.

Information for Marketing and Promotional Purposes

We also collect and store personal information, such as name, address, email address, telephone number, gender, previous purchases, birth date, health information (only if you purchase the Dueple Swiit products and only for the potential presumption that you are interested in socks for diabetics) and other contact information [please confirm and complete], if you subscribe to our newsletter, for the purpose of sending you information on new products, sales, promotional materials, direct mailing and targeted advertising on products that we believe you may be interested in. We do so only if you have given your explicit, free and informed consent for such purposes. In line with the GDPR we will always give you the opportunity to opt in to our mailing list and without your consent we will not add you to our mailing list to receive direct marketing or market research information.  

Information for the maintenance and Improvement of our Website and Services

We may also use your personal information, such as web server logs, IP addresses, cookies, pixel tags and web beacons, when you send us inquiries regarding our products or when you browse the website, to administrate and improve this website or our products and services, for our internal records and for statistical analysis, as set forth in our Cookie Policy [Note: insert link].

Cookies, pixels and web beacons

This website may also collect cookies, pixels and web beacons subject to our Cookie Policy available at [please insert link to Cookie Policy]. You can always change your cookie preferences using your web browser and the instructions in the Cookie Policy.


Legal Basis for Processing

Our collection and processing of personal information is based on the following:

  1. need to carry out the above processing of information, which is in anticipation of entering into commercial engagements or as part of the performance of existing engagements with you, for example for providing you the goods and items that you ordered through our website.
  2. To the extent that we use the personal information for advertising or promotional activities, including direct mailing and targeted advertising, we will request your specific, freely-given, unbundled, informed and separate consent to such uses.
  3. To the extent that we use the personal information to improve this website or for analyzing statistics, the basis for collection of data is our legitimate interest to conduct such improvements and analysis.

Information sharing and disclosure

Because DUEPLE is a global company, your personal information may be shared with other DUEPLE offices or subsidiaries around the world. All such entities are governed by this Privacy Policy or are bound by the appropriate confidentiality and data transfer agreements.

DUEPLE may share your personal information with other companies or people under any of the following circumstances:

  1. when we have your consent to share the information;
  2. we need to send the information to third parties who work on behalf of DUEPLE to provide a product or service to you (we will only provide those companies the information they need to deliver the product, and they are prohibited from using that information for any other purpose), for example for shipping and handling purposes, credit card payment services, etc.;
  3. in the event of sale or transfer of all or substantially all of DUEPLE or any DUEPLE affiliate’s shares or assets, in cases of mergers or in case of negotiations with respect to the foregoing;
  4. to our service providers and subcontractors in order to keep you up to date on the latest product announcements, special offers or other information we think you would like to hear about either from us or from our business partners (unless you have opted out of these types of communications), subject to your opt-in consent to such processing activities; or
  5. Where needed for corporate audits or to investigate or respond to a complaint or security threat, to prevent illegal uses of our services, to defend ourselves against third party claims and assist in fraud prevention or investigation.
  6. We will also disclose your personal information if required to do so by law, or in urgent circumstances, to protect personal safety, the public or our website.

We will not sell or otherwise transfer the personally identifiable information you provide to us at our Websites to any third parties for their own direct marketing use unless we provide clear notice to you and obtain your explicit consent for your data to be shared in this manner.

For the above purposes, personal information may be transferred to recipients in countries around the world (which may be located outside the EU/EEA, European Economic Area) which in some cases may have a lower level of protection than that within the EU/EEA. When transferring personal data to countries outside the EU/EEA, to jurisdictions that did not receive an adequacy decision by the European Commission, we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal information. The standard contractual clauses can be found via the following link: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.


Data Retention

DUEPLE stores the personal information as long as it is necessary to fulfil the purpose for which the data has been collected. This means that DUEPLE deletes your personal information when such information is no longer necessary, unless we have a legitimate interest to retain such data for longer periods or are required to do so by any applicable law. Statistics which has been anonymized may be saved thereafter. [Please confirm that such retention policies are in place]


Data Subject Rights

If you are a resident of the EU/EEA, you may at any time request the rectification or erasure of your personal information. Please note however that deletion could mean that DUEPLE cannot process your requests or provide you any requested services. You have the right to request a copy of your personal information from our record. You have the right to request a limitation of the use of your personal information (for example if you deem the information to be incorrect) or the termination of use of your personal information (for example as regards the use of the information to improve our services).

If you have a DUEPLE account, you can opt-out of receiving marketing communications by modifying your preferences in the "view or change my profile" section of our website. You can also opt-out by modifying your email or SMS subscriptions by clicking on the unsubscribe link or following the opt-out instructions included in the message. Alternatively, you can contact us using the contact details below.


Data security

DUEPLE safeguards the security of the data you send us with physical, electronic, and managerial procedures, taking into consideration the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of processing your personal information. While we strive to protect your personal information, we cannot ensure the security of the information you transmit to us, and so we urge you to take every precaution to protect your personal data when you are on the Internet.


Third party sites

Our website may contain links to websites operated by other companies. DUEPLE does not share your personal information with those websites and is not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies. Some of these third-party sites may have permission to include the DUEPLE logo, even though they are not operated or maintained by DUEPLE. Although we choose our business partners carefully, DUEPLE is not responsible for the privacy practices of websites operated by third parties that are linked to our site. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you. We may provide services based on third party applications and content tools on the DUEPLE website such as [please provide examples for third party apps you use]. These third parties may automatically receive certain types of information whenever you interact with us on our website using such third party applications and tools, based on such third parties’ privacy statements.


Changes to this privacy policy

DUEPLE will amend this policy from time to time. If we make any substantial changes in the way we use your personal information we will make that information available by posting a notice on this site.


Privacy Inquiries

DUEPLE is responsible for the processing of your personal data, and requests to exercise your rights as stated above shall be addressed to [Insert contact information of DPO]

If you are a resident of the EU/EEA, and have a complaint regarding the processing of your personal data by DUEPLE you are entitled to report such dissatisfaction to the applicable supervisory authority in your country of residence.