PRIVACY POLICY

This Privacy Policy explains how TITRE TROIS collects, uses, stores, shares and protects personal data when you visit https://titretrois.com, create an account, place an order, contact us, subscribe to marketing communications or otherwise interact with our Website.

This Privacy Policy applies to customers and Website users worldwide.

Depending on your country of residence, additional mandatory data protection rights may apply. Nothing in this Privacy Policy is intended to limit any rights that cannot legally be excluded or restricted under applicable law.

1. WHO WE ARE

The Website https://titretrois.com is operated by:

Individual Entrepreneur “Galiullina”
trading under the brand TITRE TROIS
registered under the laws of the Republic of Kazakhstan
info@titretrois.com  // titretrois@gmail.com

For the purposes of applicable data protection legislation, TITRE TROIS acts as the data controller, meaning that we determine why and how your personal data is processed.

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal data collected when you:

  • visit or browse the Website;
  • create or use a customer account;
  • place or attempt to place an Order;
  • make a payment;
  • request delivery or return of a Product;
  • contact customer support;
  • communicate with us by email, telephone or other available communication channels;
  • subscribe to newsletters or other marketing communications;
  • interact with our advertisements;
  • submit a return, refund or complaint request; or
  • otherwise interact with TITRE TROIS.

This Privacy Policy does not apply to third-party websites, platforms or services that have their own privacy policies.

3. PERSONAL DATA WE COLLECT

We collect only personal data that is reasonably necessary for the purposes described in this Privacy Policy.

Depending on how you interact with TITRE TROIS, we may collect the following categories of information.

3.1 Identification and Contact Information

This may include:

  • first name;
  • last name;
  • telephone number;
  • email address;
  • billing address;
  • delivery address;
  • country and city of residence; and
  • other contact information you choose to provide.

3.2 Order and Transaction Information

This may include:

  • Order number;
  • Products purchased;
  • size, colour and other Product selections;
  • Order value;
  • currency;
  • delivery method;
  • payment method;
  • payment status;
  • transaction reference;
  • return and refund information;
  • purchase history; and
  • correspondence relating to the Order.

3.3 Payment Information

Payments may be processed by independent third-party payment providers.

TITRE TROIS does not normally receive or store your complete bank card number, CVV/CVC code or full payment card credentials where those details are entered directly into the secure environment of the payment provider.

We may receive limited payment-related information necessary to identify and manage a transaction, such as:

  • payment status;
  • transaction ID;
  • payment method;
  • currency;
  • amount;
  • date of payment; and
  • limited card information, such as the last digits of a card, where provided by the payment processor.

Payment providers process payment data in accordance with their own privacy policies and applicable financial and data protection regulations.

3.4 Delivery and Customs Information

For international Orders, Delivery Services, customs authorities or other parties involved in customs clearance may require additional information.

Where necessary and legally permitted, this may include:

  • full legal name;
  • telephone number;
  • delivery address;
  • country of residence;
  • tax or customs identification information; and
  • identity document information where specifically required by customs or applicable law.

TITRE TROIS does not collect passport numbers, identity document numbers, IINs or copies of identity documents as part of the ordinary checkout process unless such information is genuinely required for a specific transaction, customs procedure or legal obligation.

We aim to collect only the minimum information necessary for the relevant purpose.

4. ACCOUNT INFORMATION

If customer accounts are available on the Website and you create an account, we may process:

  • your name;
  • email address;
  • telephone number;
  • account login information;
  • saved addresses;
  • Order history;
  • preferences; and
  • other information associated with your account.

Passwords should be stored using appropriate security protections and should not be accessible to TITRE TROIS in plain text where the Website infrastructure supports secure password hashing.

You are responsible for keeping your login credentials confidential.

5. INFORMATION YOU PROVIDE WHEN CONTACTING US

If you contact TITRE TROIS, we may collect the information contained in your communication, including:

  • your name;
  • email address;
  • telephone number;
  • Order number;
  • photographs provided in connection with returns, defects or complaints;
  • messages and correspondence; and
  • any other information you voluntarily provide.

Please avoid sending sensitive personal information unless it is reasonably necessary for resolving your request.

6. INFORMATION COLLECTED AUTOMATICALLY

When you visit the Website, certain technical information may be collected automatically.

Depending on the technologies used by the Website and your cookie preferences, this may include:

  • IP address;
  • browser type and version;
  • device type;
  • operating system;
  • language settings;
  • approximate location derived from an IP address;
  • referring website or page;
  • pages viewed;
  • date and time of access;
  • session information;
  • interactions with Website features;
  • cookie identifiers;
  • advertising identifiers; and
  • other technical information.

We use this information for purposes including Website security, functionality, analytics, fraud prevention, performance measurement and, where permitted, advertising.

7. COOKIES AND SIMILAR TECHNOLOGIES

The Website may use cookies, pixels, tags, local storage and similar technologies.

Cookies are small data files stored on your device or browser.

We may use the following categories of cookies and similar technologies:

Strictly Necessary Cookies

These cookies are required for the Website to operate and may be used for:

  • maintaining Website security;
  • remembering shopping bag contents;
  • processing checkout;
  • maintaining user sessions;
  • preventing fraud; and
  • providing essential Website functionality.

Where permitted by applicable law, these cookies do not require consent because the Website cannot operate properly without them.

Functional Cookies

These technologies may remember preferences such as:

  • language;
  • currency;
  • region; and
  • other Website settings.

Analytics Cookies

Where enabled, analytics technologies help us understand:

  • how visitors use the Website;
  • which pages are viewed;
  • how users navigate through the Website;
  • Website performance; and
  • technical problems.

Advertising and Marketing Technologies

Where enabled, advertising technologies may be used to:

  • measure advertising performance;
  • understand whether a purchase or Website visit resulted from an advertisement;
  • build advertising audiences;
  • limit repeated advertising;
  • personalize advertising; and
  • show relevant TITRE TROIS advertisements on third-party platforms.

This may involve third-party advertising and analytics providers.

Where required by applicable law, non-essential analytics and advertising technologies will only be activated after you have provided the required consent.

You can accept, reject or adjust non-essential cookie preferences through the cookie consent tool available on the Website, where provided.

Withdrawing or refusing consent to non-essential cookies does not prevent you from placing an Order or using essential Website functions.

More detailed information about specific cookies, providers and their duration should be available through the Website’s Cookie Settings or separate Cookie Policy.

8. PURPOSES FOR WHICH WE USE PERSONAL DATA

We may process personal data for the following purposes:

Processing and Fulfilling Orders

Including:

  • accepting Orders;
  • verifying Order information;
  • processing payments;
  • preparing Products for dispatch;
  • communicating Order confirmations;
  • arranging delivery;
  • providing tracking information;
  • handling returns and refunds; and
  • resolving Order-related issues.

Customer Service

Including:

  • responding to enquiries;
  • processing complaints;
  • assisting with Products;
  • responding to return requests; and
  • providing support.

Payments and Fraud Prevention

Including:

  • verifying transactions;
  • detecting suspicious activity;
  • preventing fraudulent Orders;
  • protecting our customers; and
  • protecting TITRE TROIS against financial loss or misuse.

Delivery and Customs Clearance

Including:

  • sharing necessary delivery information with courier and logistics providers;
  • arranging international delivery;
  • completing customs procedures; and
  • complying with import/export requirements.

Website Operation and Security

Including:

  • maintaining and improving Website functionality;
  • diagnosing technical problems;
  • protecting accounts;
  • preventing unauthorized access;
  • maintaining security logs; and
  • protecting the Website against fraud, abuse and cyber threats.

Legal and Regulatory Compliance

Including:

  • accounting and tax requirements;
  • consumer protection obligations;
  • payment and financial compliance;
  • customs requirements;
  • responding to lawful requests from authorities;
  • preventing unlawful activity; and
  • establishing, exercising or defending legal claims.

Analytics and Improvement

Where permitted by law, we may use Website usage information to understand customer behaviour and improve:

  • Website functionality;
  • navigation;
  • Products;
  • customer experience; and
  • marketing performance.

Marketing

Where permitted by applicable law, we may send information about:

  • new collections;
  • Products;
  • special offers;
  • events;
  • editorial content; and
  • other TITRE TROIS news.

Where consent is required, marketing communications will only be sent after you have provided valid consent.

9. LEGAL BASES FOR PROCESSING

The legal basis used for processing depends on the purpose, the type of personal data and the law applicable to the individual.

Where the EU GDPR, UK GDPR or similar legislation applies, we may rely on one or more of the following legal bases:

Performance of a Contract

We process personal data where necessary to:

  • process your Order;
  • take payment;
  • deliver Products;
  • process returns and refunds; or
  • otherwise perform our contract with you.

Steps Taken at Your Request Before Entering Into a Contract

For example, where you contact us with a question about a Product or prospective Order.

Legal Obligation

We may process information where necessary to comply with:

  • tax requirements;
  • accounting obligations;
  • customs requirements;
  • consumer protection law;
  • court orders; or
  • other legal obligations.

Legitimate Interests

Where permitted by law, we may process personal data where necessary for legitimate business interests, including:

  • preventing fraud;
  • securing the Website;
  • managing customer service;
  • protecting legal rights;
  • improving business operations; and
  • understanding Website performance.

We use legitimate interests only where those interests are not overridden by the individual’s rights and freedoms.

Consent

We rely on consent where required, including for certain:

  • marketing communications;
  • advertising cookies;
  • analytics cookies; and
  • cross-border transfers or other processing where applicable law specifically requires consent.

Consent can be withdrawn at any time, without affecting processing lawfully carried out before withdrawal.

Where the legislation of the Republic of Kazakhstan requires consent to the collection, processing or transfer of personal data, such consent will be obtained in a manner that allows the consent to be confirmed.

10. MARKETING COMMUNICATIONS

Receiving marketing communications from TITRE TROIS is optional.

Where required by applicable law, we will obtain your consent before sending marketing communications.

You may unsubscribe at any time by:

Withdrawing marketing consent will not affect your ability to place Orders or receive transactional communications relating to an existing Order.

Even after you unsubscribe, we may retain limited information necessary to maintain a suppression record and ensure that we do not send marketing communications to you again.

Transactional emails, such as Order confirmations, delivery notifications, security communications and return information, are not marketing communications and may continue where necessary to provide the service.

11. WHEN WE SHARE PERSONAL DATA

TITRE TROIS does not disclose personal data to third parties except where reasonably necessary for the purposes described in this Privacy Policy or where required by law.

Personal data may be shared with the following categories of recipients.

Payment Providers

For:

  • payment processing;
  • refunds;
  • transaction verification; and
  • fraud prevention.

Delivery, Courier and Logistics Providers

For:

  • delivery of Orders;
  • returns;
  • tracking;
  • customs clearance; and
  • resolving delivery issues.

Customs and Government Authorities

Where required for:

  • import or export procedures;
  • customs clearance;
  • taxation;
  • legal compliance; or
  • lawful government requests.

Website, Hosting and IT Service Providers

Where necessary for:

  • Website hosting;
  • database management;
  • cybersecurity;
  • backups;
  • technical support;
  • communications; and
  • other Website infrastructure.

Customer Relationship and Communication Providers

Where used to provide:

  • customer support;
  • email communications;
  • account management; and
  • transactional notifications.

Analytics and Advertising Providers

Where enabled and permitted by applicable law, information may be processed by analytics or advertising partners for:

  • Website analytics;
  • conversion measurement;
  • advertising attribution;
  • audience creation; and
  • personalized advertising.

Non-essential advertising and analytics technologies will be subject to consent where such consent is required by applicable law.

Professional Advisers

Personal data may be disclosed where reasonably necessary to:

  • lawyers;
  • accountants;
  • auditors;
  • insurers;
  • consultants; or
  • other professional advisers.

Business Transfers

If all or part of the TITRE TROIS business is reorganized, transferred, merged or sold, relevant personal data may be transferred as part of that transaction, subject to appropriate legal safeguards.

12. SALE OR SHARING OF PERSONAL DATA

TITRE TROIS does not sell personal data for monetary payment.

Certain privacy laws may define the terms “sale”, “share” or similar concepts more broadly, particularly in relation to online advertising technologies.

Where applicable law treats the use of certain advertising or analytics technologies as a “sale” or “sharing” of personal data and provides an opt-out right, eligible users may exercise that right through the Website’s cookie/privacy settings or by contacting us.

We do not knowingly sell or share personal data of minors in a manner prohibited by applicable law.

13. INTERNATIONAL DATA TRANSFERS

TITRE TROIS is established in the Republic of Kazakhstan and sells Products internationally.

As a result, personal data may need to be transferred between countries in connection with:

  • payment processing;
  • international delivery;
  • customs clearance;
  • Website infrastructure;
  • IT services;
  • customer communications;
  • analytics; or
  • advertising.

Where the legislation of the Republic of Kazakhstan requires personal data to be stored in a database located within the Republic of Kazakhstan, TITRE TROIS shall comply with such requirement.

Cross-border transfers from Kazakhstan are carried out in accordance with applicable Kazakhstan legislation, including requirements relating to protection in the destination country and consent where applicable.

Where the EU GDPR applies and personal data is transferred to a country that is not recognized as providing an adequate level of data protection, appropriate legal safeguards may be used, including the European Commission’s Standard Contractual Clauses, where applicable.

Where the UK GDPR applies, appropriate safeguards may include the UK International Data Transfer Agreement (IDTA) or the applicable UK Addendum to the European Commission Standard Contractual Clauses.

Other legally recognized transfer mechanisms may be used where appropriate.

Where consent is legally required for a particular international transfer, we will obtain that consent.

14. DATA STORAGE AND RETENTION

We do not keep personal data indefinitely simply because it has been collected.

Personal data is retained only for as long as reasonably necessary for the purpose for which it was collected, including applicable legal, accounting, tax, customs, consumer protection and dispute-resolution requirements.

Retention periods depend on the category and purpose of the information.

Order and Transaction Information

Order, payment and transaction records may be retained for the period necessary to:

  • fulfil the Order;
  • process returns;
  • comply with accounting and tax requirements;
  • comply with consumer protection law; and
  • establish or defend legal claims.

Customer Account Information

Account information may be stored while the account remains active and for a reasonable period afterwards where necessary for security, legal compliance or dispute resolution.

Users may request deletion of their account subject to any information we are legally required to retain.

Customer Service Communications

Customer service correspondence may be retained for as long as reasonably necessary to resolve the matter and protect the parties’ legitimate legal interests.

Marketing Information

Marketing preferences are retained until consent is withdrawn or the information is no longer necessary.

Limited suppression information may be retained after an opt-out to ensure that the individual’s marketing preference continues to be respected.

Cookies

Cookie retention periods vary depending on the type of cookie.

Further information should be made available through the Website’s cookie consent tool or Cookie Policy.

Security Information

Security logs and related technical data may be retained for the period reasonably necessary to:

  • investigate incidents;
  • prevent fraud;
  • secure the Website; and
  • comply with legal obligations.

After the applicable retention period, personal data will be deleted, destroyed or anonymized, unless continued retention is required or permitted by applicable law.

15. DATA SECURITY

TITRE TROIS takes reasonable organizational, administrative and technical measures designed to protect personal data against:

  • unauthorized access;
  • unlawful processing;
  • accidental loss;
  • destruction;
  • alteration;
  • disclosure; and
  • misuse.

Such measures may include, where appropriate:

  • controlled access to personal data;
  • password protection;
  • encryption;
  • secure communications;
  • access logging;
  • backups;
  • staff access restrictions;
  • security monitoring; and
  • contractual confidentiality obligations.

No online service or method of electronic storage can be guaranteed to be completely secure. We therefore cannot guarantee absolute security, but we take reasonable measures appropriate to the nature and risks of the processing.

16. PERSONAL DATA BREACHES

If a personal data breach occurs, TITRE TROIS will assess the nature and potential consequences of the incident and take reasonable measures to limit and remedy its effects.

Where required by applicable law, we will notify the appropriate data protection or regulatory authority.

Where applicable law requires affected individuals to be informed of a breach, we will provide the required notification within the legally applicable period.

17. YOUR PRIVACY RIGHTS

Your rights depend on the privacy and data protection laws applicable to you.

Subject to applicable legal conditions and exceptions, you may have the right to:

  • obtain information about how your personal data is processed;
  • request access to your personal data;
  • request correction of inaccurate or incomplete information;
  • request deletion of personal data;
  • request restriction of processing;
  • object to certain processing;
  • receive certain personal data in a structured, commonly used and machine-readable format;
  • request transfer of eligible data to another organization;
  • withdraw consent;
  • object to direct marketing; and
  • lodge a complaint with a competent data protection authority.

Not every right applies in every jurisdiction or in every circumstance.

18. RIGHTS OF USERS IN THE EUROPEAN ECONOMIC AREA

Where the EU GDPR applies, you may have the following rights:

  • Right of access – to obtain confirmation of whether we process your personal data and receive a copy;
  • Right to rectification – to correct inaccurate or incomplete personal data;
  • Right to erasure – to request deletion where the legal requirements are met;
  • Right to restriction – to restrict processing in certain circumstances;
  • Right to data portability – to receive eligible personal data in a structured and machine-readable format;
  • Right to object – including the right to object at any time to processing for direct marketing;
  • Right to withdraw consent – where processing is based on consent;
  • Rights relating to automated decision-making – where applicable; and
  • Right to lodge a complaint with a competent data protection supervisory authority.

Where applicable, requests will generally be handled without undue delay and within the period required by the GDPR.

You may lodge a complaint with the supervisory authority in your country of residence, place of work or the place of an alleged infringement, subject to applicable law.

19. RIGHTS OF USERS IN THE UNITED KINGDOM

Where UK data protection legislation applies, users may have equivalent or similar rights under the UK GDPR and applicable UK data protection legislation, including rights of:

  • access;
  • rectification;
  • erasure;
  • restriction;
  • portability;
  • objection;
  • withdrawal of consent; and
  • complaint to the UK Information Commissioner’s Office or other competent authority, as applicable.

20. RIGHTS UNDER KAZAKHSTAN LAW

Where the legislation of the Republic of Kazakhstan applies, individuals have rights relating to their personal data, including the right to:

  • know whether TITRE TROIS holds personal data relating to them;
  • obtain information about the purposes, sources and methods of collection and processing;
  • obtain information concerning the categories of personal data processed;
  • request correction or supplementation of inaccurate personal data where legally supported;
  • withdraw consent to collection and processing, subject to applicable legal restrictions;
  • request blocking or destruction where provided by law; and
  • exercise other rights granted by applicable legislation.

Where consent is withdrawn, TITRE TROIS will stop the relevant processing within the period required by Kazakhstan law unless continued processing or storage is required or permitted by law.

21. USERS IN OTHER COUNTRIES

Customers in other jurisdictions may have additional rights under local privacy, data protection or consumer legislation.

Where mandatory local law provides rights or protections beyond those described in this Privacy Policy, those mandatory provisions will apply.

To exercise a privacy right, please contact us using the details below.

22. HOW TO EXERCISE YOUR RIGHTS

Privacy requests may be submitted to:

info@titretrois.com  // titretrois@gmail.com

Please include enough information for us to understand and process your request.

For security purposes, we may request additional information where reasonably necessary to verify your identity before providing access to, deleting or modifying personal data.

We will not request excessive identification information solely for the purpose of exercising a privacy right.

Requests will be processed within the timeframe required by applicable law.

Certain rights may be subject to legal limitations. For example, we may be required to retain transaction information for tax, accounting, fraud prevention or legal purposes even after a deletion request.

23. AUTOMATED DECISION-MAKING AND PROFILING

TITRE TROIS does not currently make decisions based solely on automated processing that produce legal effects or similarly significant effects on customers, unless otherwise disclosed and permitted by applicable law.

Advertising and analytics providers may use automated technologies to categorize interests or measure advertising performance.

Where such processing requires consent, it will only occur after the necessary consent has been obtained.

Where applicable law grants rights in relation to profiling or automated decision-making, those rights remain unaffected.

24. CHILDREN’S PRIVACY

The Website is not specifically directed at children.

TITRE TROIS does not knowingly seek to collect personal data from children where such collection would require parental or guardian consent under applicable law.

If you believe that a child has provided personal data to us unlawfully, please contact info@titretrois.com  // titretrois@gmail.com so that we can investigate and take appropriate action.

25. THIRD-PARTY WEBSITES AND SERVICES

The Website may contain links to third-party websites or services.

TITRE TROIS is not responsible for the privacy practices of independent third parties.

When you follow a third-party link or interact directly with a third-party service, the collection and use of your personal data by that provider is governed by its own privacy policy.

We encourage you to review the relevant privacy information before providing personal data to third-party services.

26. CHANGES TO THIS PRIVACY POLICY

TITRE TROIS may update this Privacy Policy from time to time to reflect:

  • changes in law;
  • changes in our Website;
  • changes in payment or delivery methods;
  • new service providers;
  • changes in data processing practices; or
  • other operational developments.

The latest version will be published on the Website with the updated “Last updated” date.

Where required by applicable law, material changes will be communicated to users and additional consent will be obtained where necessary.

Continued use of the Website does not constitute consent to new processing activities where applicable law requires separate consent.

27. GOVERNING DATA PROTECTION LAW

TITRE TROIS is established in the Republic of Kazakhstan and complies with applicable Kazakhstan personal data protection legislation.

Because TITRE TROIS sells Products internationally, additional data protection legislation may also apply depending on the location of the individual and the nature of the processing.

This may include, where applicable:

  • the EU General Data Protection Regulation (GDPR);
  • applicable national laws of EU/EEA Member States;
  • the UK GDPR and applicable UK data protection legislation; and
  • other mandatory privacy or data protection laws applicable to particular customers or processing activities.

Nothing in this Privacy Policy is intended to exclude rights granted under mandatory applicable data protection law.

28. CONTACT US

For questions about this Privacy Policy or the processing of your personal data, or to exercise a privacy right, please contact:

TITRE TROIS
Individual Entrepreneur “Galiullina”
Email: info@titretrois.com  // titretrois@gmail.com
Registered address: Republic of Kazakhstan, Almaty city, 121 Bogenbay Batyr st.