Privacy Policy

Welcome to our website www.laberde.com (hereinafter, the “Site”). For Ugur Aydin LABERDE Advertising your privacy and the security of your personal data are very important. That is why we collect and manage your personal data with the utmost attention, and adopt specific measures to safely store it. Below you will find key information about how your personal data is processed when you navigate through the Site and use the services offered. For detailed information about how LABERDE process your personal data, please carefully read this document (Privacy Policy)‎‎. Please also read the ‎‎Cookie Policy‎‎ and the Site Terms of Use, which contain detailed information about, respectively, the use of cookies and similar technologies on the Site, and about the terms relating to our services. Some services may be subject to specific legal terms, in which case it will be our responsibility to duly inform you in each instance.

This Privacy Policy exclusively refers to the Site, and does not concern any third party websites referred to within the pages of the Site.

The Site is managed by LABERDE, a single-member company subject to the management and coordination activity of For Ugur Aydin LABERDE Advertising, with registered office at via Cihangir Avcılar Istanbul, Turkey. Which acts as independent personal data controller for all activities related to the online sale of LABERDE products, such as the signing and performance of the contract; payment; invoice issuance; product shipping; any management of the right of withdrawal, return, and the legal guaranties; the control and prevention of fraud and abusive behaviours; registration on the Site (“My Account”), and the use of services reserved for registered users (for example: Wish List, My Orders, Quick Buy, etc.); the following services are offered to you through the Site (not available in all countries): (i) delivery of products purchased online at the LABERDE stores (“pick up in store”), (ii) return of products purchased online at the LABERDE stores (“return in store”), and (iii) online sale of products at the LABERDE stores (“click from store”); as well as any corresponding assistance that is provided by ‎‎Customer Care (further information is available in point 3.1) and fulfilment of the legal obligations for personal data processing (more information in point 3.4). LABERDE, with registered office at Istanbul, Turkey (LABERDE) acts as independent data controller for the purposes of marketing, profiling, and sharing your data for these purposes, whenever you provide your express consent to such processing (more information is available in point 3.3). LABERDE also acts as data controller for the services offered through the Site, reserving a product online at LABERDE stores (“click & reserve”, not available in al countries) and finding the LABERDE stores closest to you (“Store Locator”) (more information is available in point 3.2), as well as for fulfilling the legal obligations for personal data processing (more information is available in point 3.4). For any clarification, question, or requirement related to your privacy, or to exercise your rights under the Turkish personal data processing legislation (the Kişisel Verileri Koruma Kanunu. 6698, hereinafter “KVKK”).

As concerns the purposes of the processing indicated in point 3 below, we process various types of personal data concerning you, including:

• your identification information (such as first and last name), your contact details (such as email address and telephone number), shipping address and billing address, payment information (such as the method of payment used, cardholder, card number used). This data is processed by Ugur Aydin LABERDE Advertising in reference to the online sale of LABERDE products and the corresponding activities related thereto (such as the signing and performance of the contract; payment; invoice issuance, product shipping; any management of the right of withdrawal, return, and the legal guaranties; customer care; the control and prevention of fraud and abusive behaviours, including by third parties, which conflict with the current standards, the applicable contractual provisions, the rules of correctness and good faith), as well as for the following services offered through the Site and connected to online sales (not available in all countries): (i) delivery of products purchased online at LABERDE stores (“pick up in store”); (ii) return of products purchased online at LABERDE stores (“return in store”); and (iii) online sale of products at LABERDE stores (“click from store”). For customer care activities, the information you choose to provide in your communications is also processed;

• if you register on the Site (“My Account”), this includes your identification information, your email address, and your password, as well as the data needed to provide you with services that are reserved for registered users (for example: Wish List, My Orders, Quick Buy, etc.). For registration/authentication of My Account via Facebook (Facebook Ireland Ltd. Service, which acts as an independent data controller) we collect the data needed for your registration/authentication from this third party. My Account and the relative services reserved for registered users are managed by Ugur Aydin LABERDE Advertising;

• your identification and contact information are also used by LABERDE to manage any requests you may have for information relating to the LABERDE products, as well as to provide you with any service (that you have requested and that is offered through the Site) to reserve a product online at LABERDE stores (“click & reserve”, not available in all countries);

• your geographic location, which is used with your consent by LABERDE for any service (that you have requested and that is offered through the Site) to find the LABERDE store closest to you (“Store Locator”);

• your identification and contact details may be processed when you give your consent to receive by phone, email, or any other means, marketing communications from or on behalf of LABERDE, or communications from or on behalf of commercial partners of LABERDE with which, with your express consent, LABERDE has shared your personal data in conformity with this Privacy Policy;

• when you have provided the corresponding consent, LABERDE also processes the data relating to your preferences and interests, such as products you’ve purchased or added to your wish list, age and gender, your country, and your preferred language and currency, the newsletters you have subscribed to and the interaction between them and events in the Armani world. LABERDE process your data to analyse your habits and preferences to offer you personalised services and communications that are in line with your interests;

• your first name, last name, and mailing address, as well as your contact information (such as email address and phone number) when a user of the Site provides your data to us in order to send you certain products purchased from the Site. We process your data only to fulfil the request from our user, and never for other purposes (for example, marketing). When you provide us with personal data from third parties, you must do whatever is necessary so that the communication of data to LABERDE and our subsequent processing for the purposes specified in this Privacy Policy occur in accordance with the applicable legislation. Therefore, prior to providing us with a third party’s personal information, you must inform them and obtain their consent to processing, where required.

When you navigate through the Site, we also collect data relating to your navigation, in particular to verify the proper functioning of the Site, to provide you with the best navigation, and to increase the quality of our services. For more information about the technologies used (cookies and similar tools) please consult our ‎‎Cookie Policy.

Ugur Aydin LABERDE Advertising, as an independent controller, processes your personal data for the online sale of LABERDE products and the relative activities connected thereto. In particular, to:

• enter into and perform a contract for the purchase on the Site of one or more products, for payment, product shipping, any management of the right of withdrawal, return, and the legal warranty. This processing is necessary to perform a contract to which you are party (purchase and sale agreement). You must provide your personal data; otherwise you will not be able to make a purchase on the Site or manage any requests you may have regarding the right of withdrawal, return, and legal warranty, or to receive the dedicated customer service;

• customer care. Processing is necessary to perform a contract to which you are party (provision of customer care). You must provide your personal data; otherwise you will be unable to receive the customer care you requested;

• the fulfilment of the legal obligations relating to the sales activity (such as, for example, issuing and storing the invoice). This processing is necessary to fulfil a legal obligation to which Ugur Aydin LABERDE Advertising is subject. It is thus mandatory that you provide your personal data; otherwise you will be unable to make a purchase on the Site;

• register on the Site (“My Account”), or use the services that are reserved for registered users (for example: Wish List, My Orders, Quick Buy, etc.). This process is necessary to perform a contract to which you are party (registration on the Site and the relative provision of services). It is mandatory that you provide your personal data; otherwise you will be unable to register on the Site and use the registered user services;

• prevention and suppression of fraud and abusive behaviours (including by third parties) that conflict with the current standards, the applicable contractual provisions, and the rules of correctness and good faith. The lawfulness of this processing is based on the legitimate interest of Ugur Aydin LABERDE Advertising to perform security activities and controls for the purpose of preventing and protecting against fraudulent activities and abusive behaviours. Upon your request, Ugur Aydin LABERDE Advertising will be able to provide you with detailed information about the aforementioned legitimate interest and the corresponding so-called balancing test;

• the use of the following services offered through the Site and linked to the online sale (not available in all countries): (i) delivery of products purchased online at LABERDE stores (“pick up in store”); (ii) return of products purchased online at LABERDE stores (“return in store”); and (iii) online sale of products at LABERDE stores (“click from store”). This processing is necessary to perform a contract to which you are party (provision of the corresponding service). It is mandatory that you provide your personal data; otherwise, you will be unable to use the service.

You may also contact LABERDE to get more information about the world of LABERDE and its products.

LABERDE processes the personal data you provide when you use these services on the Site and enter the corresponding areas of the Site. The processing is based on the performance of a contractual obligation between the parties or on precontractual measures adopted upon your request. It is mandatory that you provide your personal data; otherwise, you would be prevented from using the requested service.

With your consent, which is optional, LABERDE uses your personal data for marketing purposes. Indeed LABERDE may send you promotions, commercial or advertising communications about its products, services, and events. The marketing activities may also include market research and surveys to determine your level of satisfaction and to conduct statistical analyses, including using aggregated anonymous data. The processing of your data is based on your voluntary consent, and providing your data is optional. However, without it, you will be unable to purchase our products online.

With your optional consent, LABERDE uses the data collected in its stores and online, through this or other sites, or through LABERDE accounts on social media, to collect information relating to your preferences, habits, lifestyle, as well as details about what you have purchased. The data is used to create group and/or individual profiles (“profiling”) which allow us to send you personalised communications that are in line with your interests, or to conduct market research and statistical analyses, including with aggregated anonymous data. The processing of your data is based on your voluntary consent, and providing your data is optional. However, without it, you will be unable to purchase our products online.

With your optional consent, LABERDE shares your personal data with companies in the LABERDE, and others operating in the beauty, lifestyle, food, or sports sector. These companies will process your data for their own marketing purposes, i.e. to send you promotions, commercial or advertising communications about their products, services, events, including market research and surveys to determine your level of satisfaction and to conduct statistical analyses, including with anonymous data, organised in aggregate form. The processing of your data is based on your voluntary consent; providing your data is optional. However, without it, you will be unable to purchase our products online.

To send you marketing communications or personalised offers, methods such as email, newsletters, operator-assisted telephone calls, SMS, MMS, chat, instant messaging, social networks and traditional mail, including invitations to organised events from LABERDE or in which LABERDE  participates. You may unsubscribe from newsletters in the corresponding section of your personal account or by clicking the respective link, which appears at the bottom of every commercial communication.

Your personal data is processed by each controller, within their own area of authority, and also for:

• managing requests to exercise personal data protection rights (further information in point 6). This processing is necessary to fulfil a legal obligation to which the data controller is subject;

• other personal data protection requirements. Under certain circumstances, the personal data protection legislation requires the data controller to use your contact details to provide you with specific information about the processing of your data such as, for example, to inform you of any security violations concerning your information and the measures adopted to address them (so-called data breach), and well as to inform you of any significant updates to this privacy policy. This processing is therefore necessary to perform a legal obligation to which the data controller is subject.

Duly informed personnel (employees and associates) of LABERDE and Ugur Aydin LABERDE Advertising, as well as third parties (providers and/or business partners) who were appropriately selected by the controllers and offer a suitable guarantee of compliance with personal data processing rules, may have access to your personal data. These third parties, based on an appropriate designation by the controllers (each of them with respect to their own area of authority) may conduct their activities as “data processors” (thus under the direct responsibility of the data controller who designated them: for example, Internet providers, companies specialised in IT and electronic services, customer care service companies, companies that perform marketing activities, companies specialised in market research and data processing, physical stores) or as “independent data controllers (for example, couriers and shippers, bank operators, independent professionals, or consulting, legal or tax assistance firms).

Your personal data may also be disclosed to third parties, including in the following cases:

(i) when disclosure is required by the applicable laws and regulations for legitimate third party recipients of communications, such as public entities and authorities that process your data as independent controllers for the respective institutional purposes;

(ii) in case of extraordinary operations (for example mergers, acquisitions, disposal of business, etc.);

(iii) when you provide your consent to the companies of the Laberde for independent marketing purposes.

You may request an updated list of the parties to whom we disclose your data by contacting us using the contact details indicatedbelow.

Some of the parties indicated above may also be established outside the Turkey, in countries that do not guaranty an adequate level of protection of personal data according to the standards established by the KVKK. LABERDE and Ugur Aydin LABERDE Advertising have adopted the necessary precautions to ensure a lawful transfer of data . You may request information about the transfer of your personal data abroad at any time by contacting us using the contact details indicatedbelow.

We retain your personal data for a limited period of time, which is strictly related to the purpose for which it was collected, and in conformity with the applicable legal or regulatory obligations. At the end of the established retention period, your personal data will be deleted, or in any case irreversibly anonymised, unless LABERDE and Ugur Aydin LABERDE Advertising is required to retain the data for an additional period of time to comply with legal or regulatory obligations, or to exercise or defend a right in a judicial proceeding.

The retention period differs according to the purpose of the processing, in particular:

• for the online sale of products and the relative activities connected thereto (point 3.1), your personal data will be retained by Ugur Aydin LABERDE Advertising for the entire duration of the contractual relationship and for 10 (ten) years after the termination thereof, except for registration on the Site (“My Account”) and the use of confidential services for registered users (for example: Wish List, My Orders, Quick Buy, etc.), in relation to which your personal data will be retained until you request the deletion of your account;

• when LABERDE processes your data for personalised marketing or profiling purposes, your data is retained for a period of 7 (seven) years from the time you provide your consent for the aforementioned purposes, following an evaluation of the impact on data protection conducted by LABERDE, with the participation of its Data Protection Officer;

• for general marketing activities, your data is retained by LABERDE until deletion is requested, consent revoked, or processing opposed; LABERDE furthermore wishes to protect your data and ensure that you wish to continue to receive its communications. Therefore, it deletes your data when 4 (four) years have elapsed since your last interaction with the LABERDE sphere, for example through purchases made at LABERDE stores or the Site, participation in LABERDE events or newsletters;

• to comply with legal obligations relating to personal data processing matters (point 3.4), your personal data will be processed by each controller, as concerns their specific area of authority, for the period needed to manage your request to exercise the rights recognised under the KVKK or to meet the legal obligation to which the data controller is subject. The data necessary to demonstrate compliance with the legal obligations to which the controller is subject shall be retained for 10 (ten) years;

• in case of a legal or administrative dispute, your data shall be retained for the time needed for unless LABERDE or Ugur Aydin LABERDE Advertising or a third party to seek legal protection of a right, or within the limits imposed by the legal or administrative authority.

For more information about the retention of your personal data, contact us using the contact details indicated below.

You may contact each data controller or the respective Data Protection Officers at any time, using the contact details specified below, to exercise your rights pursuant to the KVKK, and particular:

• to obtain confirmation of whether or not your personal data is being processed and, if it is, to obtain access to or a copy of such personal data (”right of access”);

• correction of your personal data, i.e. to obtain the correction, modification, or updating of any data that is inaccurate or no longer correct, as well as to supplement incomplete personal data, including by providing a supplementary declaration (“right of rectification”);

• to revoke your consent (“right to revoke consent”): you may revoke the consent you have given to process your personal data at any time, including in relation to any activity whatsoever with a marketing purpose, including profiling. To that end, we remind you that marketing activities are considered to be the sending of commercial and advertising communications, the completion of market research and surveys to determine level of satisfaction, and the personalisation of commercial offers based on your interests. Once your request has been received, the controller will be responsible for stopping the processing of your personal data that was based on such consent, while different instances of processing, or processing based on other requirements, will continue to be performed in full compliance with the current provisions;

• to request the deletion of your personal data when such data, in particular, (i) is no longer necessary for the purposes for which it was collected or processed, or (ii) was unlawfully processed, or (iii) must be deleted to perform a legal obligation, or, lastly, (iv) you have opposed such processing (see below “right to object”) and there is no prevailing legitimate reason that would allow the controller to nevertheless proceed with the processing (“right to erasure” or “right to be forgotten”);

• to obtain a limitation on the processing of your personal data, i.e. that the controller retains such data, but without being able to use it, save for any requests or exceptions prescribed by law. This right may only be exercised when, in particular (i) you object to the accuracy of the personal data, for the period needed for the controller to verify the accuracy of such personal data, or (ii) the processing of data is unlawful and you ask to limit its use, instead of deleting it, or (iii) even though the controller no longer needs it for processing purposes, you require the personal data to assess, exercise, or defend a right in a legal proceeding, or (iv) you have opposed its processing (see below “right to object”), while awaiting a verification as to any legitimate grounds of the controller that prevail over those of the data subject (right to restriction);

• to request your data or transfer it to a party other than the controller (“right to data portability”). You may ask to receive the data we process based on your consent or based on a contract entered with you, in a form that is structured, commonly used, and readable on an automatic device. If you so desire, where technically possible, we may, upon your request, transfer your data directly to a third party you indicate;

• submit a claim to one of the competent supervisory authorities on compliance with the personal data protection standards, if you believe that your data was unlawfully processed (“right to submit a claim”).

Furthermore, as a data subject, you also have the “right to object”, i.e.:

• object at any time, for reasons related to your specific situation, to the processing of your personal data for the purpose of a legitimate interest of the controller or for marketing purposes, including profiling. The controller shall refrain from further processing your personal data, unless it demonstrates that there are compelling, legitimate reasons to proceed with the processing that prevail over the interests, rights, and freedoms of the data subject, or to assess, exercise, or defend a right in judicial proceedings.

To ensure full respect of the rights described above, and that our users’ data is not unlawfully accessed or violated by third parties, prior to accepting a request from you to exercise one of the rights indicated, we may ask you for certain information to confirm your identity or clarify the request made.

The features, functionalities, and services offered by the Site may undergo changes in the future. Consequently, this Privacy Policy may be changed and supplemented over time. Therefore, we ask that you please periodically check the contents thereof. We will arrange to inform you in a timely manner of any significant changes that are made to this Privacy Policy.

LABERDE uses some of your personal data to send you personalised notifications about products and commercial news (so-called “web push notification”) on your device, upon your express consent. In order to be able to send you these notices, we use technologies similar to cookies (in particular, “HTLM5 Local Storage”), which archive information in your device’s Local Storage area. Some of your personal data is also stored on servers, located in the Turkey, which are used to manage the “web push notification”. Communications are personalised based on how you navigate and use the Site and, in particular on the products you have viewed, purchased, or placed in your cart, or on the data you entered on the Site registration form or when purchasing products on the Site (in particular, your name, to personalise communications sent to you and your date of birth to offer you special birthday promotions and discounts. The categories of personal data that are used for this purpose are:

• products that are purchased, viewed, or placed in your cart;

• name;

• date of birth;

• gender (male or female); language used to navigate and version of the Site used (country);

• information about the device and browser you used;

• date and time when you gave consent to receive web push notifications;

• date My Account created;

• date of last visit to Site.

You may revoke your consent to receiving personalised commercial communications at any time by following the instructions below, depending on your browser.

Main browsers:

• Chrome: Settings > Show Advanced Settings > Privacy – Content Settings > Notifications - Manage exceptions > Enter www.laberde.com and select “Block”

• Firefox: Options > Content > Notifications – Choose > www.laberde.com – “Block”

• Safari: Preferences > Notifications > From here select “Refuse”.

You may also revoke your consent to receiving these notices from the communications you receive, by following the instructions below.

• Desktop: Right-click on notifications> disable notifications from www.laberde.com

• Mobile: Access the notification centre > Site parameters > Notifications > Block notifications from www.laberde.com

In any case, the service and your corresponding personal data in the possession of LABERDE will be deleted after 365 (three hundred sixty-five) days from the date of your last visit to the Site.

We adopt specific technical and organisational security measures to safeguard the confidentiality of Site users’ personal data, which are aimed at preventing the unlawful or fraudulent use of their personal data.

We remind you to take suitable precautions when using the Site, such as, for example, keeping your access credentials strictly private, and changing them periodically.

Last updated March 20th, 2021.