Last Updated: December 2025

1. Identity of the Data Controller

In compliance with the Turkish Law on the Protection of Personal Data (Law No. 6698 - "KVKK") and the General Data Protection Regulation (EU) 2016/679 ("GDPR"), your personal data is processed by HTC VE LVN TEKSTİL MOBİLYA AYAKKABI SANAYI TICARET LIMITED SIRKETI (trading as "L'EAUPHANT") as the Data Controller.

Registered Address: Merkez Mh., Çifte Cevizler Cad., Saruhan Plaza 23/65 Şişli / ISTANBUL – TURKEY

Contact: customercare@leauphant.com

2. Scope and Global Compliance

L'EAUPHANT is committed to protecting the privacy of our clients worldwide. This policy outlines how we collect, use, and safeguard your information across our global operations, ensuring compliance with:

• Turkey: KVKK (Law No. 6698)
• Europe/UK: GDPR (General Data Protection Regulation)
• USA: CCPA (California Consumer Privacy Act) and general federal standards.
• International: Applicable local data protection laws in the regions where we ship.

3. Personal Data We Collect

We collect specific categories of personal data to provide our services and the "L'EAUPHANT Experience."

3.1. Data Categories:

• Identity Data: First name, last name, username or similar identifier.
• Contact Data: Billing address, delivery address, email address, and telephone numbers.
• Financial Data: Payment card details (processed securely via encrypted third-party gateways like Iyzico/Stripe; L'EAUPHANT does not store raw credit card numbers).
• Transaction Data: Details about payments to and from you and other details of products you have purchased from us.
• Technical Data: Internet Protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
• Profile & Marketing Data: Your interests, preferences, feedback, and survey responses; and your preferences in receiving marketing from us (subject to consent).

4. Purposes and Legal Basis for Processing

Under GDPR and global standards, we process your data based on specific legal grounds outlined below:

4.1. Order Fulfillment

• Purpose: Processing your order, managing payments, and delivering products.
• Legal Basis: Contractual Necessity (Performance of a contract with you).

4.2. Customer Support

• Purpose: Managing returns, exchanges, and inquiries.
• Legal Basis: Contractual Necessity & Legitimate Interest.

4.3. Fraud Prevention

• Purpose: Protecting our platform and your account from unauthorized activities.
• Legal Basis: Legitimate Interest & Legal Obligation.

4.4. Marketing

• Purpose: Sending newsletters, exclusive offers, and collection updates.
• Legal Basis: Consent (Explicit consent provided by you/opt-in).

4.5. Legal Compliance

• Purpose: Tax reporting, customs declarations, and regulatory requirements.
• Legal Basis: Legal Obligation.

4.6. International Data Transfers

As L'EAUPHANT operates globally and utilizes Shopify Inc. as our e-commerce infrastructure provider, your personal data may be transferred to, stored, and processed in countries outside of your country of residence (including Canada and the United States).

• Safeguards: We ensure that such transfers are compliant with applicable laws. For transfers out of the European Economic Area (EEA), we rely on Adequacy Decisions (e.g., for Canada) or Standard Contractual Clauses (SCCs) approved by the European Commission to ensure your data remains protected.

6. Sharing of Your Data

We do not sell your personal data. We only share it with trusted third parties essential to our operations:

• Logistics Partners: (e.g., DHL, UPS, Local Couriers) for order delivery.
• Payment Processors: (e.g., Iyzico, Stripe, PayPal) for secure transaction processing.
• Service Providers: Shopify (platform hosting), email service providers, and analytics providers (Google Analytics).
  Legal Authorities: Customs authorities, tax agencies, and courts, where required by law.

7. Cookie Policy

L'EAUPHANT uses cookies and similar technologies (pixels, tags) to enhance your browsing experience, analyze site traffic, and personalize content.

7.1. Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the website to function (e.g., secure login, keeping items in your cart). These cannot be switched off.
• Performance & Analytics Cookies: Allow us to count visits and traffic sources so we can measure and improve the performance of our site (e.g., Google Analytics).
• Functional Cookies: Enable the website to provide enhanced functionality and personalization (e.g., remembering your currency or language).
• Targeting/Advertising Cookies: May be set through our site by our advertising partners to build a profile of your interests and show you relevant adverts on other sites.

7.2. Managing Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please note that if you disable or refuse cookies, some parts of this website may become inaccessible or not function properly.

8. Your Global Privacy Rights

Depending on your location, you have specific rights regarding your personal data.

8.1. For Clients in Europe (GDPR) & Turkey (KVKK):

You have the right to:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate data.
• Erasure: Request deletion of your data ("Right to be Forgotten"), subject to legal retention periods (e.g., tax laws).
• Restriction: Request restriction of processing.
• Portability: Receive your data in a structured, machine-readable format.
• Objection: Object to processing based on legitimate interests or direct marketing.

8.2. For Clients in the USA (California - CCPA/CPRA):

• Right to Know: You may request details about the categories of personal information we collect and share.
• Right to Delete: You may request the deletion of your personal information.
• Non-Discrimination: We will not discriminate against you for exercising your privacy rights.
• "Do Not Sell/Share": While L'EAUPHANT does not sell personal data for monetary value, you have the right to opt-out of the sharing of data for cross-context behavioral advertising.

8.3. For Clients in the Middle East & Rest of World:

We are committed to respecting your privacy and will honor requests to access, correct, or delete your data in accordance with applicable local laws and our global standards.

How to Exercise Your Rights:

To exercise any of these rights, please contact us at customercare@leauphant.com. We will respond to your request within 30 days.

9. Data Security

We have implemented appropriate security measures (SSL encryption, PCI-DSS compliance) to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way. Access to your personal data is limited to those employees, agents, and partners who have a business need to know.

10. Marketing Communications

You will only receive marketing communications (newsletters, collection launches) from us if you have requested information from us or purchased goods from us and have not opted out of receiving that marketing. You can ask us to stop sending you marketing messages at any time by following the "Unsubscribe" link on any marketing message sent to you.

L'EAUPHANT reserves the right to update this policy to reflect changes in our practices or legal obligations.