PRIVACY POLICY
[22 June 2026]Privacy Policy
1. Introduction
As Cipro Investment and Trading Ltd. (“we” or “us”), we attach the utmost importance to the privacy of personal data and data processing.
This Privacy Policy (the “Policy”) explains how we collect, use, share, and protect your personal data, as well as your rights and how you can exercise those rights, when you interact with us through our website, our stores, any of our communication channels, or through our other products and services.
2.Scope of the Policy
Our Website and other digital channels (collectively, the “Platforms”) may be subject to restrictions under applicable local laws. For more detailed information regarding such restrictions, please refer to the Terms of Use. Due to these restrictions, the Platforms may be inaccessible in whole or in part from certain countries or jurisdictions, or certain content may not be available. Accordingly, we would like to note that, depending on the location of the data subjects whose personal data is processed, certain data processing activities described in this Policy may not apply. For more detailed information regarding the scope of personal data processing activities, you may contact us at kvk@ciprogroup.com.
3. Processing of Your Personal Data
The personal data processed may vary depending on your location. Detailed information regarding the processing of personal data of individuals residing in Northern Cyprus is set out under Section 3.1. Information on the processing of personal data of individuals residing outside Northern Cyprus is provided under Section 3.2.
3.1. For Individuals Residing in Northern Cyprus
We collect, compile, process, share, transfer to other countries, and store your personal data in accordance with the Personal Data Protection Law No. 89/2007 (the “Law”), as well as the regulations, by-laws enacted under this Law, and all other applicable regulations, including those issued by the Northern Cyprus Personal Data Protection Authority. For further information regarding our obligation to inform you about the processing of your personal data, you may refer to the Personal Data Information Notice.
3.1.1. Data Controller
The data controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data, establishes and operates the personal data filing system, and has the authority and responsibility for its supervision. In this respect, our details as the data controller are as follows:
Cipro Investment and Trading Ltd.
Semih Sancar Caddesi, No. 2A
Girne, KKTC
3.1.2. Methods of Data Collection
Your personal data may be collected directly from you through the Platforms, as well as through other methods. In this respect, we may collect your personal data through the following methods:
· Collection directly from the data subject through the personal data you provide via digital or physical forms when registering, either in person or through digital channels, to benefit from our various commercial channels, Platforms, or other products and services (for example, surveys, offers, campaigns, Ploom Club),
· Collection directly from the data subject or by our employees in cases where device identification is carried out in our stores or via the Platforms,
· Collection directly from the data subject through the personal data you provide when subscribing to informational emails or commercial communications,
· Collection directly from the data subject when you use our Platforms or complete forms available on our Platforms (please refer to the Cookie Policy for information regarding cookies)[BA1] ,
· Collection directly by our store personnel during device registration processes at the time of device purchases.
Further detailed information regarding the collection of your personal data is provided in the information notices presented to you at the time your personal data is collected.
3.1.3. Personal Data Collected
As the data controller, we collect your personal data as set out below. In the event of any changes to the personal data we collect, detailed information regarding any additional personal data collected will be provided in the relevant information notice at the time of collection:
· Personal Information:
o Name surname,
o Date of birth/age,
o Country of residence,
o Telephone number,
o Email.
· Website transaction security:
o User information,
o User session / access information.
· Purchase transaction:
o Purchase information,
o Return/Exchange/after-sales transaction information,
o Billing information
3.1.4. Legal Purposes for Processing Your Personal Data
In accordance with Article 5(1) of the Law, we collect and process your personal data in a lawful and fair manner; for specific, explicit, and legitimate purposes; and in a manner compatible with those purposes. We ensure that your personal data is accurate and, where necessary, kept up to date. While fulfilling the purposes for which personal data is collected and processed, we do not retain such data for longer than necessary in a form that permits identification of your identity, subject to the discretion of the Authority. We collect and process your personal data in accordance with the legal processing grounds set out below:
· Where you, as the data subject, provide your consent in a manner that leaves no room for doubt.
· Where the processing is necessary for the fulfilment of our legal obligations.
· Where the processing is necessary for the performance of a contract to which you, as the data subject, are a party, or in order to take steps at your request prior to entering into such a contract.
· Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by the rights, interests, or fundamental freedoms of the data subject.
The processing activities listed above are referred to as “legal processing”. As the data subject, your personal data is processed based on the legal grounds set out in the table below. In the event that processing is carried out on a legal basis other than those specified below, you will be informed again, in accordance with the Law and the Regulation on the Procedures and Principles for Fulfilling the Obligation to Inform, regarding the new legal basis for processing, in compliance with the applicable local legislation:
Purpose of data processing | Legal basis for processing
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For the purpose of conducting age verification in order to ensure that products and services are provided to individuals who meet the legally required age limits under applicable laws. | Where the processing is necessary for the fulfilment of our legal obligations.
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For the purpose of entering into a contract with the consumer within the scope of the provision of products and services, and for the performance, monitoring, and completion of obligations arising under such contract. | Where the processing is necessary for the performance of a contract to which you, as the data subject, are a party, or for taking steps at your request prior to entering into such a contract. |
For the purpose of enabling consumers to benefit from campaigns, programs, services, or applications in compliance with applicable laws. | Where you, as the data subject, provide your consent in a manner that leaves no room for doubt
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For the purpose of providing consumers with informative and promotional communications regarding our potential products and services, or informing consumers about the availability of such communications | Where you, as the data subject, provide your consent in a manner that leaves no room for doubt,
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For the purpose of addressing your issues, suggestions, and complaints as a consumer, fulfilling our obligations arising primarily from the Consumer Protection Law and other applicable local legislation, and providing after-sales services related to our products and services. | · Where the processing is necessary for the performance of a contract to which you, as the data subject, are a party, or for taking steps at your request prior to entering into such a contract; · Where the processing is necessary for the fulfilment of our legal obligations; · Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by the rights, interests, or fundamental freedoms of the data subject.
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For the purpose of sending consumers informative messages and promotional communications via communication channels such as SMS and email regarding products and services, including those of third parties, | Where you, as the data subject, provide your consent in a manner that leaves no room for doubt,
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For the purpose of transmitting to you informative messages and promotional communications of third parties, | Where you, as the data subject, provide your consent in a manner that leaves no room for doubt, |
For the purpose of carrying out, monitoring, supervising, and finalizing our activities in order to ensure customer satisfaction and improve customer experience in relation to our products and services, as well as through our Platforms (for detailed information on the use of cookies on the Platforms, please refer to the Cookie Policy). | · Where you, as the data subject, provide your consent in a manner that leaves no room for doubt; · Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by the rights, interests, or fundamental freedoms of the data subject.
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For the purpose of conducting consumer surveys and market research.
| · Where you, as the data subject, provide your consent in a manner that leaves no room for doubt.
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In the event that you become a member of Ploom Club, for the purpose of providing you with the services listed below: · For the purpose of creating your Ploom Club membership, updating your account information, enabling password setup processes, and closing your account; · Earning points; · Viewing the points you have earned in your Ploom Club account; · Using your available points for purchases, earning points, or receiving discounts in various ways; · Benefiting from personalized campaigns. For further information regarding Ploom Club, please refer to the FAQ section. | In the event that you create a Ploom Club membership:
· Where you, as the data subject, provide your consent in a manner that leaves no room for doubt; · Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by the rights, interests, or fundamental freedoms of the data subject; · Where the processing is necessary for the performance of a contract to which you, as the data subject, are a party, or for taking steps at your request prior to entering into such a contract.
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For the purpose of fulfilling the data processing purposes described above: · For the purpose of carrying out internal operations, including the management of the Platforms, data analysis, testing, research and statistics, and troubleshooting; · For the purpose of ensuring that the content of the Platforms and the data of the data subjects are kept up to date, · For the purpose of ensuring the data security of the Platforms, · For the purpose of maintaining data logging on the Platforms, managing traffic, and ensuring accessibility, For detailed information regarding cookies, please refer to the Cookie Policy.
| Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by the rights, interests, or fundamental freedoms of the data subject
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For the purpose of fulfilling legal obligations and conducting legal, judicial, administrative, and/or other legal proceedings, as well as responding to official requests received from judicial or administrative authorities
| Where the processing is necessary for the fulfilment of our legal obligations
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3.1.5. Sharing of Your Personal Data & Transfer to Other Countries
Your personal data may be shared with individuals and entities located within Northern Cyprus as well as with countries outside Northern Cyprus. The transfer of data to countries outside Northern Cyprus shall be carried out in accordance with the provisions of the Law, subject to the existence of a valid transfer authorization and at least one of the conditions set out below.
Your personal data may be shared with the persons specified below for the purposes set out below:
Purpose of sharing personal data | Legal basis | Recipient groups
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For the purpose of fulfilling our after-sales warranty obligations and providing technical support within the scope of our products or services.
| Where the processing is necessary for the performance of a contract to which you, as the data subject, are a party, or for taking steps at your request prior to entering into such a contract,
| JT International SA, its affiliates, their subsidiaries, and other JTI group companies located abroad.
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For the purpose of enabling, assigning, monitoring, and finalizing the benefits provided under the Ploom Club membership, including campaigns, discounts, or other similar offerings
| · Where the processing is necessary for the performance of a contract to which you, as the data subject, are a party, or for taking steps at your request prior to entering into such a contract, · Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by the rights, interests, or fundamental freedoms of the data subject
| · JT International SA, its affiliates, their subsidiaries, and other JTI group companies located abroad. · Other service providers engaged within Northern Cyprus.
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For the purpose of carrying out, monitoring, ensuring continuity of, and finalizing our product and service procurement processes.
| Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party to whom the data is disclosed, except where such interests are overridden by the rights, interests, or fundamental freedoms of the data subject
| · JT International SA, its affiliates, their subsidiaries, and other JTI group companies located abroad. · Other service providers engaged within Northern Cyprus
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For the purpose of enabling consumers to exercise their rights under applicable laws and fulfilling our legal obligations within the scope of consumer rights pursuant to local legislation | Where the processing is necessary for the fulfilment of our legal obligations
| · JT International SA, its affiliates, their subsidiaries, and other JTI group companies located abroad. · Other service providers engaged within Northern Cyprus |
For the purpose of fulfilling legal obligations and conducting legal, judicial, administrative, and/or other legal proceedings, as well as responding to official requests received from judicial or administrative authorities | Where the processing is necessary for the fulfilment of our legal obligations
| Judicial and administrative authorities and institutions in Northern Cyprus
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For the purpose of carrying out, monitoring, improving, and finalizing the processes related to the benefits of Ploom Club membership, in the event that a Ploom Club membership is created.
| Where the data subject has given consent to the transfer, provided that such consent is given in a manner that leaves no room for doubt and is not contrary to law or accepted moral principles.
| · Third parties located abroad from whom infrastructure and software services are procured. · JT International SA, its affiliates, their subsidiaries, and other JTI group companies located abroad.
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For the purpose of maintaining records relating to our products or services, improving product and service processes, responding to inquiries within such processes, and ensuring, monitoring, maintaining continuity of, and finalizing customer communications
| · For the purpose of the completion or performance of a contract concluded between the data subject and the controller or between the controller and a third party for the benefit of the data subject, · For taking steps at your request prior to entering into a contract between you, as the data subject, and the controller.
| · Third parties located abroad from whom infrastructure and software services are procured. · JT International SA, its affiliates, their subsidiaries, and other JTI group companies located abroad.
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For the purpose of establishing communication in relation to products or services, managing communication preferences, ensuring the continuity of communication, and terminating communication.
| Where the data subject has given consent to the transfer, provided that such consent is given in a manner that leaves no room for doubt and is not contrary to law or accepted moral principles
| · Third parties located abroad from whom infrastructure and software services are procured. · JT International SA, its affiliates, their subsidiaries, and other JTI group companies located abroad.
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For the purpose of obtaining server services to ensure the secure storage of personal data, as well as improving, securing, and maintaining the continuity of such server services
| Where the data subject has given consent to the transfer, provided that such consent is given in a manner that leaves no room for doubt and is not contrary to law or accepted moral principles.
| · Third parties located abroad from whom infrastructure and software services are procured · JT International SA, its affiliates, their subsidiaries, and other JTI group companies located abroad.
|
3.1.6 Retention of Your Personal Data
Your personal data may be stored on servers located outside Northern Cyprus in accordance with the Law and applicable local legislation. Where necessary, we may transfer your personal data to other servers for storage purposes, provided that we fulfil our obligations, including the obligation to inform, in compliance with the Law and relevant local regulations.
While ensuring the fulfilment of the purposes for which personal data is collected and processed, we do not retain such data for longer than necessary in a form that permits the identification of your identity, subject to the discretion of the Authority. Depending on the purpose for which your personal data is obtained, your personal data will be retained for the periods prescribed by applicable legislation after the termination of the relevant processing purpose, taking into account factors such as warranty periods related to our products or services, contractual obligations between us as a customer relationship, and benefits such as campaigns or Ploom Club membership, as well as tax or other legal obligations arising under applicable laws. For further details regarding the retention of your personal data, you may contact us.
3.1.7 Confidentiality and Security of Processing
Personal data processing activities are carried out solely by us as the data controller, or by persons acting under our authority, and only in accordance with the instructions provided by us in our capacity as the controller. Within the scope of ensuring the confidentiality and security of processing, appropriate organizational and technical measures are implemented, including but not limited to the following:
· We select individuals who possess appropriate qualifications, provide sufficient technical competence, and demonstrate personal reliability in maintaining confidentiality for the purpose of carrying out processing activities.
· We implement appropriate organizational and technical measures to ensure the confidentiality and protection of data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure, or access, as well as any other unlawful forms of processing. These measures ensure a level of security appropriate to the risks associated with the processing activities and the nature of the data.
It is extremely important that you ensure the password you set through our Platforms is secure, that you choose a password different from those you use on other platforms, and that you do not share your passwords with anyone.
3.1.8 Legal Rights
Pursuant to Articles 14 and 15 of the Law, we would like to remind you of your rights arising from the applicable local legislation of Northern Cyprus. Under the Law, everyone has the right to know whether their personal data is being processed. As the data subject, you may, either directly or with the assistance of an expert:
· All personal data relating to you that has been processed, as well as the source of such data,
· The purposes of the processing, the recipients or categories of recipients to whom the data is disclosed, and the categories of data that have been or are being processed,
· the progress recorded in the processing since the previous notification,
· the rectification, erasure, or blocking of data, in particular where processing has not been carried out in accordance with the provisions of the Law due to inaccuracies or deficiencies,
· Notification to third parties to whom the data has been disclosed, regarding any rectification, erasure, or blocking carried out pursuant to Article 14(2)(B) of the Law, insofar as this is not impossible or does not involve disproportionate effort,
You may contact us via kvk@ciprogroup.com or through the Contact Us page to request or obtain such information. Your request submitted in this manner will be responded to within a maximum of 30 (thirty) days.
In addition, at any time, based on legitimate reasons related to your specific situation, you may submit a written objection, including a request for the performance or non-performance of certain actions such as rectification, temporary restriction of use, blocking, refusal of transfer or erasure, non-processing, or deletion of your personal data that has been processed, is being processed, or is planned to be processed, by contacting us via kvk@ciprogroup.com or through the Contact Us page.
While exercising your legal right of access and objection as described herein, a fee may be charged to you in accordance with Article 37(2) of the Law. In the event that your request for the rectification or erasure of your data is deemed justified, the corrected version of the data relating to you will be provided to you without delay, free of charge, and in an intelligible form.
For detailed information regarding the exercise of your legal rights, you may contact us via kvk@ciprogroup.com or through the Contact Us page.
3.2 Individuals Residing Outside Northern Cyprus
The products and services made available through the Platforms may be subject to restrictions under the laws and regulations applicable in your country. Accordingly, the personal data processed may vary. For detailed information regarding the personal data processed, you may contact us via kvk@ciprogroup.com or through the Contact Us page.
3.2.1 Data Controller
The data controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data, establishes and operates the personal data filing system, and has the authority and responsibility for its supervision. In this respect, our details as the data controller are as follows:
Cipro Investment and Trading Ltd.
Semih Sancar Street, No. 2A
Kyrenia, TRNC
3.2.2. Methods of Data Collection
Your personal data may be collected directly from you through the Platforms, as well as through other methods. In this respect, we may collect your personal data through the following methods:
· Collection directly from the data subject through the personal data you provide via digital or physical forms when registering, either in person or through digital channels, to benefit from our Platforms or other products and services,
· Collection directly from the data subject or by our employees in cases where device identification is carried out in our stores or via the Platforms,
· Collection directly from the data subject through the personal data you provide when subscribing to informational emails or commercial communications,
· Collection directly from the data subject when you use our Platforms or complete forms available on our Platforms (please refer to the Cookie Policy for information regarding cookies)[BA2]
· Collection directly by our store personnel during the device registration process at the time of device purchases.
Further detailed information regarding the collection of your personal data is provided in the information notices presented to you at the time your personal data is collected.
3.2.3. Personal Data Collected
As the data controller, we collect your personal data as set out below. In the event of any changes to the personal data we collect, detailed information regarding any additional personal data collected will be provided in the relevant information notice presented to you at the time of collection:
· Personal Informations:
o Name surname,
o Date of birth/age,
o Country of residence,
o Telephone number,
o Email.
· Website transaction security:
o User information,
o User session / access information.
· Purchase transaction:
o Purchase information,
o Return/Exchange/after-sales transaction information,
o Billing information.
3.2.4. Conditions for Processing of Personal Data
We process your personal data in compliance with the law and the principles of good faith; ensuring that it is accurate and, where necessary, kept up to date; for specific, explicit, and legitimate purposes; in a manner that is relevant, limited, and proportionate to the purposes for which it is processed; and we retain it only for the period stipulated by applicable legislation or required for the purposes for which it is processed.We collect and process your personal data in accordance with the processing conditions set out below:
· Where your explicit consent is obtained as the data subject,
· Where it is expressly provided for by law,
· Where the processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract,
· Where it is mandatory for the data controller to fulfil its legal obligations,
· Where data processing is necessary for the establishment, exercise, or protection of a right,
· Where data processing is necessary for our legitimate interests, provided that it does not harm your fundamental rights and freedoms as the data subject,
As the data subject, your personal data is processed based on the processing conditions set out in the table below. In the event that processing is carried out on a legal basis other than those specified below, you will be informed again through information notices prepared in accordance with the applicable legislation.
| Legal basis for processing
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For the purpose of verifying your age in order to ensure that our products and services are provided to individuals who meet the legally required age limits under applicable local legislation.
| where it is mandatory for the data controller to fulfil its legal obligations.
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For the purpose of entering into a contract with the consumer within the scope of the provision of our products and services, and for the performance, monitoring, and completion of our obligations under such contract.
| Where the processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract.
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For the purpose of addressing your issues, suggestions, and complaints as a consumer, fulfilling our obligations arising under applicable local legislation in relation to our products and services, and providing after-sales services.
| · Where the processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract; · Where it is mandatory for the data controller to fulfil its legal obligations; · Where data processing is necessary for our legitimate interests, provided that it does not harm your fundamental rights and freedoms as the data subject; · Where data processing is necessary for the establishment, exercise, or protection of a right.
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For the purpose of carrying out, monitoring, supervising, and finalizing our activities in order to ensure customer satisfaction and improve customer experience in relation to our products and services, as well as through our Platforms (for detailed information on the use of cookies on the Platforms, please refer to the Cookie Policy).
| · Where data processing is necessary for our legitimate interests, provided that it does not harm your fundamental rights and freedoms as the data subject.
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For the purpose of fulfilling the data processing activities described above:
For detailed information regarding cookies, please refer to the Cookie Policy.
| Where data processing is necessary for our legitimate interests, provided that it does not harm your fundamental rights and freedoms as the data subject.
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For the purpose of fulfilling legal obligations and conducting legal, judicial, administrative, and/or other legal proceedings, as well as responding to official requests received from judicial or administrative authorities.
| Where it is mandatory for the data controller to fulfil its legal obligations. |
3.2.5 Sharing of Your Personal Data & Transfer to Other Countries
Your personal data may be shared with individuals and entities located within Northern Cyprus as well as with countries outside Northern Cyprus. The transfer of personal data to countries outside Northern Cyprus is carried out in accordance with the provisions of the applicable local legislation of Northern Cyprus.
Your personal data may be shared with the recipient groups specified below for the purposes outlined below:
Purpose of sharing personal data | Legal basis | Recipient groups |
For the purpose of carrying out, monitoring, ensuring the continuity of, and finalizing our product and service procurement processes
| Where data processing is necessary for our legitimate interests, provided that it does not harm your fundamental rights and freedoms as the data subject | · Other service providers engaged within Northern Cyprus.
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For the purpose of enabling consumers to exercise their rights under applicable local legislation and fulfilling our legal obligations within the scope of consumer protection laws.
| · Where it is mandatory for the data controller to fulfil its legal obligations, · Where data processing is necessary for the establishment, exercise, or protection of a right | · Other service providers engaged within Northern Cyprus.
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For the purpose of fulfilling legal obligations and conducting legal, judicial, administrative, and/or other legal proceedings, as well as responding to official requests received from judicial or administrative authorities.
| Where it is mandatory for the data controller to fulfil its legal obligations
| Judicial and administrative authorities and institutions in Northern Cyprus
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For the purpose of maintaining records relating to products or services, improving product and service processes, responding to inquiries within such processes, and ensuring, monitoring, maintaining continuity of, and finalizing customer communications
| · Where the processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract; · Where data processing is necessary for our legitimate interests, provided that it does not harm your fundamental rights and freedoms as the data subject.
| · Third parties located abroad from whom infrastructure and software services are procured; · JT International SA, its affiliates, their subsidiaries, and other JTI group companies located abroad.
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For the purpose of obtaining server services to ensure the secure storage of personal data, as well as improving, securing, and maintaining the continuity of such server services.
| Where data processing is necessary for our legitimate interests, provided that it does not harm your fundamental rights and freedoms as the data subject.
| · Third parties located abroad from whom infrastructure and software services are procured. · JT International SA, its affiliates, their subsidiaries, and other JTI group companies located abroad. |
Your personal data may be transferred to certain JTI group companies based on the existence of valid standard contractual clauses, in accordance with the provisions of applicable local legislation in your country of residence. In any case, transfers carried out from Northern Cyprus are conducted in compliance with obligations arising from local legislation, such as the existence of a valid data transfer authorization.
3.2.6 Retention of Your Personal Data
Your personal data may be stored on servers located outside Northern Cyprus in accordance with the Law and applicable local legislation. Where necessary, we may transfer your personal data to other servers for storage purposes, provided that we fulfil our obligations, including the obligation to inform, in compliance with the Law and relevant local regulations.
Your personal data is retained, depending on the purpose for which it was obtained, for the periods prescribed by applicable legislation after the completion of the relevant processing purpose, taking into account factors such as warranty periods related to our products or services, contractual obligations between us as part of the customer relationship, and other obligations arising under tax or applicable legislation. For further details regarding the retention of your personal data, you may contact us.
3.2.7 Data Security
As the data controller, the security of your personal data is an issue we attach the utmost importance to. In this regard, we take all necessary technical and administrative measures to ensure the security of your personal data, including but not limited to the following:
· To prevent the unlawful processing of personal data;
· To prevent unlawful access to personal data;
· To ensure the secure storage of personal data.
It is extremely important that you ensure the password you set through our Platforms is secure, that you choose a password different from those you use on other platforms, and that you do not share your passwords with anyone.
3.2.8 Rights of the Data Subject
We would like to remind you that, as the data subject, you have the following rights:
· To learn whether your personal data is being processed,
· If your personal data has been processed, to request information regarding such processing,
· To learn the purpose of processing your personal data and whether it is used in accordance with its purpose,
· To know the third parties to whom your personal data is transferred, whether domestically or abroad,
· To request the rectification of your personal data in case it is processed incompletely or inaccurately and to request that such rectification be notified to third parties to whom the personal data has been transferred,
· To request the erasure or destruction of your personal data in the event that the purposes for processing no longer exist, the maximum retention period prescribed by law has expired, or the purpose of processing has otherwise ceased, and to request that such action be notified to third parties to whom the personal data has been transferred,
· To object to the occurrence of a result against you arising from the analysis of processed data exclusively through automated systems,
· To request compensation for damages in case you suffer harm due to the unlawful processing of your personal data.
· You may contact us via kvk@ciprogroup.com or through the Contact Us page to submit your requests within the scope of your rights listed above. Requests submitted in this manner will be responded to within a maximum of 30 (thirty) days.
For detailed information regarding the exercise of your rights, you may contact us via kvk@ciprogroup.com or through the Contact Us page.
3.3 Processing of Personal Data of Individuals Located Outside Cyprus
Considering that the internet is a global environment, the use of the internet to collect and process personal data generally involves the international transfer of such data. If you are not a citizen of Northern Cyprus, you may be subject to various regulations in the field of personal data protection. In this respect, please contact us in order to obtain detailed information regarding the processing of your personal data.
4. Entry into Force of the Policy
This Policy shall enter into force upon its publication on www.trnc.ploom.com. The most recent amendment was made on 24/06/2026.
[BA1]Hangi yöntemlerle kişisel veriler toplanacaktır, detaylar sağlanmalı
[BA2]Türkler için: Hangi yöntemlerle kişisel veriler toplanacaktır, detaylar sağlanmalı
[BA3]Türkler için uygun mu? Türklere Ploom Club olacak mı?
