Privacy Policy

1. Who We Are

This Privacy Policy applies to Estar Tekstil Sanayi ve Ticaret Limited Şirketi, operating under the brand name Broche.

Registered address: GEPOSB, 6. Cadde, 61. Sokak, 41400, Gebze / Kocaeli, Turkey.
Email: enquiries@broche.com.tr
Phone: +90 262 751 33 75

We are a manufacturer and supplier of broderie, guipure, and lace fabrics serving fashion brands worldwide. When you use our website or contact us through our enquiry form, we may collect and process your personal data as described in this policy.

2. What Data We Collect

When you submit an enquiry through our contact or lead form, we collect the following information:

• First name and last name
• Email address
• Phone number (optional)
• Company name
• Country
• Message content (your enquiry details)

We also collect standard technical data automatically when you visit our website, including IP address, browser type, pages visited, and time of visit. This data is collected via Google Analytics and Google Tag Manager.

3. How We Use Your Data

We use the personal data you provide for the following purposes:

• To respond to your enquiry and provide you with information about our products and services
• To send you samples, quotes, or other materials you have requested
• To manage our business relationship with you
• To improve our website and marketing performance (analytics data only)

We do not use your data for automated decision-making or profiling.

4. Legal Basis for Processing

We process your personal data under the following legal bases in accordance with the General Data Protection Regulation (GDPR):

• Legitimate interests — responding to your business enquiry and maintaining our commercial relationship
• Consent — where you have explicitly provided consent, such as agreeing to this Privacy Policy when submitting a form
• Legal obligation — where required by applicable law

5. Data Sharing and Third Parties

We do not sell, rent, or trade your personal data. We may share your data with the following trusted third parties solely to operate our business:

• Zoho CRM (Zoho Corporation) — for managing enquiries and customer relationships. Data is stored on Zoho's EU servers. See Zoho's Privacy Policy.
• Google Analytics / Google Tag Manager (Google LLC) — for website analytics. Data may be transferred to the United States under Standard Contractual Clauses. See Google's Privacy Policy.
• Google Ads (Google LLC) — for advertising measurement and optimisation. Conversion data is processed in accordance with Google's data processing terms.

All third-party processors are bound by data processing agreements and are required to handle your data securely and in compliance with applicable law.

6. International Data Transfers

Broche is based in Turkey. Turkey has been assessed as providing an adequate level of data protection for transfers from the European Economic Area (EEA) in certain contexts. Where data is transferred to countries outside the EEA (such as the United States via Google services), appropriate safeguards such as Standard Contractual Clauses are in place.

7. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes outlined in this policy, or as required by applicable law. Enquiry data is generally retained for up to 3 years from the date of last contact. You may request deletion of your data at any time (see Section 9).

8. Cookies

Our website uses cookies to improve your browsing experience and to analyse website traffic. Cookies used include:

• Essential cookies — required for the website to function correctly
• Analytics cookies — Google Analytics cookies to understand how visitors interact with our site
• Advertising cookies — Google Ads conversion tracking cookies

You can manage or disable cookies through your browser settings at any time. Disabling analytics and advertising cookies will not affect your ability to use the website.

9. Your Rights

Under GDPR, if you are located in the European Economic Area or the United Kingdom, you have the following rights regarding your personal data:

• Right of access — to request a copy of the personal data we hold about you
• Right to rectification — to request correction of inaccurate data
• Right to erasure — to request deletion of your personal data
• Right to restriction — to request that we limit the processing of your data
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object — to object to processing based on legitimate interests
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, please contact us at enquiries@broche.com.tr. We will respond within 30 days.

You also have the right to lodge a complaint with your local data protection authority. In the UK this is the Information Commissioner's Office (ICO). In the EU, please contact the supervisory authority in your country of residence.

10. Data Security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. Our website uses HTTPS encryption and access to customer data is restricted to authorised personnel only.

11. Children's Privacy

Our website and services are directed at business professionals and are not intended for individuals under the age of 18. We do not knowingly collect personal data from children.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The date of the most recent update is shown at the top of this page. We encourage you to review this policy periodically.