Personal Data Protection Policy

Basic information about the protection of personal data transferred to Thrones Danışmanlık Gıda Tekstil Ve Dış Ticaret Ltd. Şti (“clooe.com.tr”) is provided below. clooe.com.tr presents the following explanations to the attention of our customers and third parties who use our website and/or mobile applications in order to fulfill the obligation to inform arising from Article 10 of the Personal Data Protection Law No. 6698 (“KVKK”). clooe.com.tr reserves the right to update this Personal Data Protection Statement at any time within the framework of changes that may be made in the current legislation.

  1. What is the legal basis for clooe.com.tr’s collection of personal data?

There are regulations in various laws regarding the use of our customers’ personal data. First of all, the principles of personal data protection have been determined with KVKK. In addition, the Law on Regulation of Electronic Commerce No. 6563 also contains provisions regarding the protection of personal data. Criminal sanctions have been envisaged in some cases for the protection of personal data through the provisions of the Turkish Penal Code No. 5237.

On the other hand, it is necessary to collect and use data in order to fulfill our obligations arising from the Consumer Protection Law No. 6502 and the Distance Contracts Regulation.

  1. What methods does clooe.com.tr use in collecting personal data?

Data provided by our customers who make transactions through www.clooe.com.tr website or mobile applications are processed by clooe.com.tr in accordance with our customers’ consents and legislative provisions.

The www.clooe.com.tr website owned by clooe.com.tr is a site that uses cookies. A cookie is a file, mostly consisting of letters and numbers, which allows the identification of the device in question by being stored in the internet browser or hard disk of the device being used.

In order to provide better service to www.clooe.com.tr visitors and within the framework of legal obligations, it will collect, process, share with third parties and securely store your browsing information, provided that it is not used outside the purposes and scope determined in this Personal Data Protection Statement.

www.clooe.com.tr cookies store the information collected through log files, blank gif files and/or third party sources in order to create a summary about your preferences. www.clooe.com.tr may track your browsing information and/or usage history on the site in order to provide you with special promotions, offer promotions and marketing offers, improve the content of the website or mobile application according to you and/or determine your preferences.

www.clooe.com.tr may match information collected from you on the site through different methods or at different times, such as information collected online and offline, and may use this information together with information obtained from other sources such as third parties.

www.clooe.com.tr mobile application uses session cookies and persistent cookies. A session ID cookie ends when you close your browser. A persistent cookie remains on your hard disk for a long time. You can remove persistent cookies and reject both session cookies and persistent cookies by following the instructions given in your internet browser’s “help” file or by visiting “www.allaboutcookies.org” or “www.youronlinechoices.eu”. If you reject persistent cookies or session cookies, you can continue to use the website and mobile application, but you may not be able to access all functions of the website and mobile application or your access may be limited.

  1. How are Website Cookies Used?

The www.clooe.com.tr website owned by clooe.com.tr is a site that uses cookies. A cookie is a file, mostly consisting of letters and numbers, which allows the identification of the device in question by being stored in the internet browser or hard disk of the device being used.

www.clooe.com.tr cookies store the information collected through log files, blank gif files and/or third party sources in order to create a summary about your preferences.

We use two types of cookies throughout our sites: session cookies and persistent cookies. Session cookies are temporary cookies and are valid only until you close your browser. Persistent cookies remain on your hard disk until you delete them or they expire (how long cookies will remain on your device will depend on the “lifetime” of the cookies).

www.clooe.com.tr cookies are used to remember your preferences and personalize your website/mobile application usage. This usage includes cookies that save your password and keep your website/mobile application session continuously open, thus saving you the trouble of entering your password multiple times on each visit, and cookies that remember and recognize you on subsequent visits to the website/mobile application.

www.clooe.com.tr uses it to determine how you use the website/mobile application, including measuring how you use the website/mobile application such as where you connect to the website, what content you view on the website/mobile application and the duration of your visit.

www.clooe.com.tr website cookies can also be used to activate “advertising technology” in order to present you with advertisements that it thinks may interest you when you visit search engines, websites, mobile applications and/or websites where the website advertises. Advertising technology uses information about your previous visits to the website/mobile application and to the websites/mobile applications where the website advertises in order to present you with personalized advertisements. When presenting these advertisements, a unique third-party cookie may be placed in your browser so that the website can recognize you. clooe.com.tr also uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to analyze with statistical information/reports how users use the website, mobile application and/or mobile site. For more information about Google Analytics usage (including opt-out options), you can visit: http://www.google.com/intl/tr/policies/privacy/#infocollect

In mobile applications, the SDK (Software Development Kit) of the relevant application is used instead of cookies.

You can use the option to allow and reject cookies using the following methods:

Google Chrome: By clicking the “lock sign” in the address section of your browser, you can allow or block cookies from the “cookies” tab.

Internet Explorer: You can manage cookies as “allow” or “do not allow” by clicking the security tab from the “Tools” section in the upper right section of your browser.

Mozilla Firefox: Click the “open menu” tab in the upper right corner of your browser. You can manage cookies by clicking the “Options” image and using the “Privacy and Security” button.

Opera: You can manage cookies from the “cookies” section by selecting “Advanced” in the “Preferences” section of your browser.

Safari: You can manage all your cookies by selecting the “safari” tab from the “Settings” section of your phone and from the “Privacy and Security” Section.

In addition to the above options; to have information about all cookies and for cookie management: you can visit https://www.allaboutcookies.org, https://www.youronlinechoices.eu/, or you can use the “Privacy Badger” application (https://www.eff.org/tr/privacybadger). If you reject persistent cookies or session cookies, you can continue to use the website, mobile application and mobile site, but you may not be able to access all functions of the website, mobile application and mobile site or your access may be limited.

Information about cookies on clooe.com.tr is provided in the tables below:

Cookie Service ProviderCookie NameCookie PurposeCookie TypeCookie Duration
Google_gaAnalytics device information – For use by applications in Google Tag Manager systemPersistent Cookie2 Years
Google_gaexpCookie holding information about AB tests – For use by applications in Google Tag Manager systemPersistent Cookie85 Days
Google_gidFor user identificationPersistent1 Day
Yandex_ym_isadFor ad blocking detectionPersistent Cookie2 Days
Yandex_ym_uidFor identifying usersPersistent Cookie1 Year
clooe.com.trAbTestingValue used for A/B Test management is stored in this cookie.Persistent Cookie2 Years
clooe.com.trWebAbTestingValues used for multiple A/B Test management are stored in this cookie.Persistent Cookie2 Years
clooe.com.trPermissions for our personal data policies are stored in this cookie.Non Persistent CookieDuring browser session
clooe.com.trCOOKIE_uicCookie where demographic information without access token belonging to logged-in user is stored.Persistent Cookie30 Minutes
clooe.com.trCOOKIE_UserAlreadyLoggedCookie where information about whether the user is already logged in is stored.Non Persistent CookieDuring browser session
clooe.com.trCOOKIE_UserTypeStatusCookie where user statuses are stored.Persistent Cookie12 Hours
clooe.com.trhvtbProvides information whether a user has previously visited clooe.com.trPersistent Cookie2 Years
clooe.com.trpidCookie where the permanently assigned user ID is stored.Persistent Cookie1 Year 354 Days
clooe.com.trsidCookie where user’s session ID value is stored.Persistent Cookie30 Minutes
clooe.com.trSiteHashCookie where hash information of cookies is stored.Persistent Cookie7 Days
clooe.com.trVisitorTypeStatusCookie where visitor statuses are storedPersistent CookieDuring browser session
Qualarooki_rPerson’s referrer cookie to the site, comes from document.referrer.Persistent Cookie5 Years
Qualarooki_tCookie containing survey timestamps and view counts.Persistent Cookie5 Years
MarketingutmCampaign30dtemp2To keep user visit channel record information for 30 daysPersistent Cookie1 Month
MarketingutmCampaignGO5dTo keep user visit channel record information for affiliate campaigns for 5 daysPersistent Cookie5 Days
MarketingutmCampaignLT30dTo keep user visit channel record information for 3 monthsPersistent Cookie1 Month
MarketingutmMedium30dtemp2To keep user visit channel record information for 30 daysPersistent Cookie1 Month
MarketingutmMediumGO5dTo keep user visit channel record information for affiliate campaigns for 5 daysPersistent Cookie5 Days
MarketingutmSource30dtemp2To keep user visit channel record information for 30 daysPersistent Cookie1 Month
MarketingutmSourceGO5dTo keep user visit channel record information for affiliate campaigns for 5 daysPersistent Cookie5 Days
  1. For what purposes does clooe.com.tr use personal data?

clooe.com.tr may record, store, update, disclose to third parties, transfer, classify and process your personal information in cases and to the extent permitted by legislation.

Your personal data is used for the following purposes:

• to verify the identity information of those who shop/have shopping done through the website/mobile applications,

• to record address and other necessary information for communication,

• to contact our customers and provide necessary information regarding the conditions, current status and updates of the contracts we have concluded under the relevant articles of the distance sales contract and the Consumer Protection Law,

• to organize all records and documents that will be the basis for transactions in electronic (internet/mobile etc.) or paper environment,

• to fulfill the obligations undertaken in accordance with the contracts we have concluded under the relevant articles of the distance sales contract and the Consumer Protection Law,

• to be able to provide information to public officials when requested and as required by legislation regarding public security issues,

• to provide our customers with a better shopping experience, to inform our customers about our products that may interest our customers “taking into account our customers’ areas of interest”, to convey campaigns,

• to increase customer satisfaction, to recognize our customers who shop from the website and/or mobile applications and to use in customer environment analysis, to use in various marketing and advertising activities and to organize surveys in electronic and/or physical environment through contracted organizations within this scope,

• to be able to offer suggestions to our customers by our contracted institutions and solution partners, to inform our customers about our services,

• to evaluate customer complaints and suggestions about our services,

• to fulfill our legal obligations and exercise our rights arising from current legislation,

  1. How does clooe.com.tr protect your personal data?

Personal data shared with clooe.com.tr is under the supervision and control of clooe.com.tr. clooe.com.tr has undertaken the responsibility as data controller to establish the necessary organization and take and adapt technical measures in order to protect the confidentiality and integrity of information in accordance with the current relevant legislative provisions. Being aware of our obligation in this regard, we would like to inform you that penetration tests are carried out at periodic intervals in accordance with international and national technical standards on data confidentiality and that we always update our data processing policies within this scope.

  1. Does clooe.com.tr share your personal data?

Sharing of personal data belonging to our customers with third parties is carried out within the framework of customer consent, and as a rule, personal data is not transferred to third parties without our customer’s approval.

However, personal data is shared with courts and other public institutions due to our legal obligations and limited to these. In addition, personal data is transferred to contracted third parties in order to provide the services we have committed to and to perform quality control of the services provided.

Necessary technical and legal measures are taken to prevent right violations during data transfer to third parties. However, clooe.com.tr is not responsible for the data protection policies of third parties receiving personal data and violations occurring in the risk area under the responsibility of third parties.

Your personal data may be shared with clooe.com.tr’s shareholders, our direct/indirect domestic/foreign affiliates, program partner institutions and organizations we cooperate with to carry out our activities, domestic/foreign persons and institutions from whom we receive cloud storage services, domestic/foreign organizations with whom we have agreements for sending commercial electronic messages to our customers, the Interbank Card Center, banks with which we have agreements, and various domestic and foreign agencies, advertising companies and survey companies within the scope of various marketing activities to provide better service and ensure customer satisfaction, and with other domestic/foreign third parties and related business partners.

  1. What are your rights arising from the Personal Data Protection Law?

In accordance with KVKK, regarding your personal data;

a. learning whether it has been processed,

b. if processed, requesting information,

c. learning the purpose of processing and whether it is used in accordance with its purpose,

d. knowing the 3rd parties to whom it has been transferred domestically/abroad,

e. requesting correction if processed incompletely/incorrectly,

f. requesting deletion/destruction within the framework of the conditions stipulated in Article 7 of KVKK,

g. requesting that the operations performed in accordance with paragraphs (d) and (e) listed above be notified to the 3rd parties to whom it was transferred,

h. objecting to the emergence of a result against you due to being analyzed exclusively by automatic systems,

i. We would like to remind you that you have the right to request compensation for damages in case you suffer damage due to processing contrary to KVKK.

j. Click for application form.

  1. How can I be informed about legislative changes regarding personal data?

The rights you have under KVKK are clooe.com.tr’s obligations. We would like to inform you that we process your personal data with this awareness and to the extent required by legislation, that we will update this information on our page in accordance with new legislation in case of legal changes, and that you can always easily follow the updates made through this page.

  1. How can I be sure that the data is kept current and accurate?

In accordance with Article 4 of KVKK, clooe.com.tr has the obligation to keep your personal data accurate and up-to-date. In this context, in order for clooe.com.tr to fulfill its obligations arising from current legislation, our customers must share their accurate and up-to-date data with clooe.com.tr. In case your data undergoes any change, we kindly ask you to update your data by contacting us through the communication channels specified below.

  1. Would you like to ask clooe.com.tr questions about your personal data?

We have a personal data storage and destruction policy. You can contact us at kvkk@clooe.com.tr e-mail address at any time for all kinds of questions and opinions about your personal data.

  1. Contact Information

COMPANY: Thrones Danışmanlık Gıda Tekstil Ve Dış Ticaret Ltd. Şti.

ADDRESS: VEYSEL KARANİ MAH. GÜLHANE CAD. SINPAŞ GYO B BLOK NO: 7 /1A SANCAKTEPE/ İSTANBUL

E-MAIL: info@clooe.com.tr

TEL: 02162259427

This contract has been prepared by THRONES DANIŞMANLIK GIDA TEKSTİL VE DIŞ TİCARET LİMİTED ŞİRKETİ. Last update date: 14.05.2025