Privacy Policy – Enis Cinar

Effective Date: 05/10/2025

1. Introduction & Data Controller

Enis Cinar (“we”, “us”, or “our”) is committed to protecting the privacy of all visitors, users, and customers of www.eniscinar.com. We process personal data responsibly to provide services, improve our offerings, and enhance user experience.

Controller Contact Information:
Enis Cinar
Hamburg, Germany
Email: impressum@eniscinar.com

We do not have a designated Data Protection Officer (DPO), but we are committed to addressing all privacy concerns promptly.

2. Scope

This privacy policy applies to:

• Visitors browsing our website
• Registered users of our services
• Customers interacting with us for purchases or inquiries

It explains what personal data we collect, why we collect it, how we use it, your rights, and how we protect your information.

3. Personal Data We Collect

We may collect the following categories of personal information:

• Contact information: Email address, phone number, postal address
• Account information: Username, password (hashed), transaction history
• Technical information: IP address, device type, operating system, browser type and version
• Interaction data: Pages visited, clicks, session duration
• Cookies and tracking data for analytics, personalization, and advertising

3.1 Google Services

We use Google services to improve our website and marketing:

Service	Purpose	Data Collected	Privacy Policy
Google Analytics	Analytics & performance tracking	Pseudonymized IP address, device/browser info, pages visited, session duration	Google Privacy
Google Ads	Advertising & audience targeting	Pseudonymized device info, cookies, IP, interactions	Google Privacy
Google Adsense	Advertising	IP address, interaction logs	Google Privacy
reCAPTCHA	Fraud prevention	Device info, IP address, browser info	Google Privacy

Note: We do not collect personal identifiers such as names, date of birth, or ID numbers via these services.

4. Legal Basis for Processing

We process personal data under the following GDPR legal grounds:

• Consent (Art. 6(1)(a)) – for marketing, analytics, and cookies requiring your permission
• Contractual necessity (Art. 6(1)(b)) – to provide services, process orders, and respond to inquiries
• Legitimate interest (Art. 6(1)(f)) – for website operation, security, and fraud prevention
• Legal obligation (Art. 6(1)(c)) – for tax, billing, and regulatory compliance

5. Data Storage and Security

Personal data is stored on secure servers located in Germany and the EU. Access is limited to authorized personnel only. We use encryption, firewalls, and monitoring systems to protect your data. All third-party service providers have Data Processing Agreements (Art. 28 GDPR) in place.

5.1 Retention Periods

We retain personal data only as long as necessary to fulfill its purpose or as required by law. After that, data is securely deleted or anonymized.

6. Sharing & Disclosure

We may share personal information with:

• Trusted service providers (e.g., hosting, analytics, payment processors)
• Legal authorities when required by law
• Third parties never for marketing purposes without your consent

All third-party processors are bound by contracts to protect your data.

7. Cookies and Tracking

We use cookies and tracking technologies to enhance your experience:

• Essential cookies – required for website functionality (no consent needed)
• Performance & Analytics cookies – for tracking usage patterns (requires consent)
• Functional cookies – to remember preferences
• Advertising/Targeting cookies – for personalized ads (requires consent)

Non-essential cookies are only activated after explicit consent via our cookie banner.

8. Your Rights

Under GDPR, you have the following rights:

1. Right of Access (Art. 15)
2. Right to Rectification (Art. 16)
3. Right to Erasure (Art. 17)
4. Right to Restriction (Art. 18)
5. Right to Data Portability (Art. 20)
6. Right to Object (Art. 21)
7. Right to Withdraw Consent (Art. 7(3))
8. Right to Lodge a Complaint (Art. 77)

Supervisory Authority for Germany:
Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit (HmbBfDI)
Ludwig-Erhard-Str 22, 7. OG, 20459 Hamburg, Germany

To exercise your rights, contact: impressum@eniscinar.com

9. Data Breach Notification

If a breach occurs that risks your personal data:

• We will assess the breach and take immediate action
• Authorities will be notified within 72 hours
• Affected individuals will be informed if there’s a high risk to their rights and freedoms
• Guidance on protective steps will be provided

10. Policy Updates

Updates may occur due to legal or operational changes. The effective date will always be indicated at the top. Major changes will be communicated via website banner or email when applicable.

11. Contact

For questions or concerns about this privacy policy: impressum@eniscinar.com

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