OUR PRIVACY AND GDPR POLICY

1. INTRODUCTION

This Privacy and Personal Data Protection and Processing Policy (“Policy”) regulates the principles regarding the processing of personal data obtained through the Shopify-based online sales platform named www.thecamelrecords.com, mobile site, social media pages, and physical event sales points operated by CAMEL RECORDS (Koray Özer Sole Proprietorship) (“CAMEL RECORDS”).

CAMEL RECORDS adopts the protection of personal data as a fundamental principle in accordance with the Law on the Protection of Personal Data numbered 6698 (“KVKK”) and relevant legislation.
The user is deemed to have given informed consent to the provisions of this Policy by visiting the site or making a transaction.

2. PURPOSE and SCOPE

This Policy ensures that all personal data collected by CAMEL RECORDS is:

processed lawfully and fairly,
for specified, explicit and legitimate purposes,
processed in a relevant, limited and proportionate manner, and
retained for the necessary period.

The Policy covers website visitors, customers, members, job applicants, suppliers, and business partners.

3. DEFINITIONS

Data Controller: Koray Özer (CAMEL RECORDS Sole Proprietorship)
Explicit Consent: Consent declaration based on information and free will.
Personal Data: Any information relating to an identified or identifiable natural person.
Special Categories of Personal Data: Sensitive data such as health, biometric, sexual life, beliefs, association memberships, etc.
Data Processor: Service providers processing personal data on behalf of CAMEL RECORDS (Shopify, payment/shipping companies, cloud providers).
Data Subject: The natural person whose personal data is processed.

4. COLLECTION OF PERSONAL DATA and LEGAL GROUNDS

Personal data is collected through:

Shopify-based website and payment systems,
Newsletter subscriptions, contact forms, social media accounts,
Festival sales points, POS devices, and email correspondence.

Legal grounds:

Establishment and performance of a contract (Art. 5/2-c),
Fulfillment of legal obligations (Art. 5/2-ç),
Establishment, exercise, or protection of a right (Art. 5/2-e),
Legitimate interest (Art. 5/2-f),
Explicit consent (Art. 5/1) required for campaigns, newsletters, advertising activities.

5. PURPOSES OF PERSONAL DATA PROCESSING

CAMEL RECORDS processes personal data for the following purposes:

Execution of membership and order transactions,
Management of shipping and invoicing processes,
Payment services (Shopify Payments, Iyzico, etc.) and refund transactions,
Customer communication and support services,
Sending campaigns, promotions, and e-newsletters (subject to explicit consent),
Security and fraud prevention measures,
Fulfillment of obligations arising from legislation.

6. TRANSFER OF PERSONAL DATA

6.1 Domestic Transfer

Personal data may be shared with:

Authorized public institutions and organizations,
Shipping, banking, payment, accounting, or IT service providers,
Consultancy and marketing business partners.

6.2 International Transfer

Data processed via Shopify Inc.'s infrastructure is stored on servers in Canada and the USA. This transfer is carried out under Standard Contractual Clauses (SCCs) and meets the adequate safeguards stipulated in KVKK Art. 9.
The same safeguard model applies to email, cloud, or analytics services (Google, Meta, Klaviyo, Mailchimp, etc.).

7. RETENTION PERIODS

Data Category	Period	Basis
Invoice and payment records	5 years	Tax Procedure Law Art. 253
Membership data	Membership period + 2 years	Legitimate interest
Commercial communication consent records	1 year	ETDHK Regulation
Communication contents	3 years	ETDHK Regulation
Log records	2 years	Law No. 5651
Customer support records	3 years	KVKK Art. 5/2-f

At the end of the period, the data is deleted, destroyed, or anonymized.

8. SECURITY OF PERSONAL DATA

CAMEL RECORDS:

uses Shopify's ISO/IEC 27001 certified infrastructure,
transmits data over encrypted (TLS/SSL) channels,
applies authorization-based access, logging, and two-factor authentication,
provides KVKK awareness training to its personnel,
informs the data subject and the KVK Board within 72 hours in case of a data breach.

9. COOKIE POLICY

The www.thecamelrecords.com website uses the following types of cookies:

Type	Purpose	Explicit Consent
Mandatory	Cart, session, security operations	No
Functional	Remembering user preferences	Yes
Analytical	Traffic analysis (Google Analytics)	Yes
Marketing	Targeted advertising and social media interaction	Yes

The user can make selections via the Cookie Preference Panel opened on their first visit or change them later.

10. RIGHTS OF THE DATA SUBJECT (KVKK Art. 11)

The data subject has the right to:

learn whether their data is being processed,
request information if it has been processed,
learn whether it is used for its intended purpose,
know the third parties to whom it has been transferred,
request rectification of incomplete or inaccurate data,
request erasure or destruction of data,
request notification of these operations to third parties,
object to a result against them arising from exclusively automated processing,
claim compensation if they suffer damage.

Applications can be made via email to info@thecamelrecords.com or in writing to the following address:

Ümit Mahallesi, 2515. Cadde Yazıkırı B Sitesi A1 Blok 2/2 Çankaya/Ankara
Requests will be answered free of charge within 30 days at the latest.

11. VERBIS and DATA PROCESSORS

CAMEL RECORDS will make the necessary notification if it becomes obliged to register with the Data Controllers' Registry in accordance with KVKK Art. 16.
Agreements with Shopify, Iyzico, Google, Meta, Klaviyo, and other service providers include Data Processing Agreement (DPA) provisions.

12. EFFECTIVENESS and UPDATES OF THE POLICY

This Policy entered into force on 01.12.2025.
CAMEL RECORDS may update the Policy in line with legal changes or technical requirements. The updated version will be published at www.thecamelrecords.com/privacy-policy.