US Data Protection Notice

CupyGift is established in Türkiye and offers personalized digital products to customers in the United States.

• name, contact and billing information;
• order, transaction, delivery and support records;
• photographs, video, audio, stories, dates, names and creative instructions;
• website, device, IP address, security and diagnostic information;
• cookie, analytics, attribution and marketing preferences;
• communications and evidence of permissions or contractual confirmations.

We do not intentionally request sensitive personal information. A photograph or story may incidentally reveal sensitive details. Customers should avoid providing unnecessary sensitive information.

Where we rely on a legitimate business interest, that interest includes service security, preventing abuse, responding to requests, improving operational reliability and defending legal rights, balanced against your rights and reasonable expectations.

Most information is collected directly from the customer through order forms, uploads, checkout, email, WhatsApp and support requests. Technical information is obtained from the device used and from the website infrastructure. A customer may also provide information about a gift recipient or another person appearing in creative materials.

If another person provides your information, the source will generally be the customer who placed the order. You may contact us to request the information we have about that source.

• hosting, storage, security and technical infrastructure providers;
• payment and fraud-prevention providers;
• email, messaging and customer-support providers;
• creative production providers bound by confidentiality and access restrictions;
• Google services used for consent-controlled analytics and measurement;
• Meta services used for consent-controlled advertising measurement and WhatsApp communication;
• accountants, lawyers, auditors and other professional advisers;
• courts, regulators, tax authorities and law enforcement where legally required.

CupyGift does not sell personal information to third parties for money. A current list of specific providers may be requested using the contact details below.

CupyGift is located in Türkiye. Information you submit is therefore processed in Türkiye and may also be processed in the United States or other countries where our service providers operate.

You may request more information about how a specific provider handles data transferred outside your home country by using the contact details below.

• Order, invoice and transaction records: for the period required by applicable tax, accounting, commercial and consumer-protection law.
• Creative source materials and deliverables: for production, revision, delivery and a limited support period, then deleted or isolated unless a dispute, legal obligation or separate permission requires longer storage.
• Support and complaint records: while the request is active and afterward for a reasonable period during which legal claims may be brought.
• Security logs: for the period necessary to detect incidents, prevent abuse and investigate security events.
• Consent records: while we rely on the permission and afterward as reasonably necessary to demonstrate the choice.
• Optional analytics and advertising data: according to the choice made and the retention settings described in the Cookie Policy.

When a fixed period cannot be stated, we apply the following criteria: whether the data is still necessary for the purpose, statutory duties, limitation periods, active disputes, security needs and whether your consent remains in place.

• the right to know what personal information we have collected, used, shared or sold about you (we do not sell personal information);
• the right to access a copy of your personal information;
• the right to correct inaccurate personal information;
• the right to request deletion of your personal information, subject to legal exceptions (for example, records we must keep for tax or accounting purposes);
• the right to opt out of the sale or sharing of personal information (CupyGift does not sell or share personal information for cross-context behavioral advertising);
• the right to limit the use of sensitive personal information, to the extent we hold any;
• the right not to be discriminated against for exercising any of these rights;
• the right to object to or opt out of marketing at any time;
• the right to withdraw consent at any time where processing is based on consent.

These rights may vary depending on your state of residence and may be subject to legal conditions and exceptions. We may ask for information reasonably necessary to verify your identity before acting on a request.

We aim to respond to privacy requests within a reasonable time and, in any event, within any deadline required by applicable state law. For example, California law generally calls for a response within 45 days, which may be extended once by an additional 45 days when reasonably necessary; we will let you know if an extension is needed.

If you believe your privacy rights have not been respected, you may also contact your state Attorney General's consumer protection office or file a complaint with the U.S. Federal Trade Commission at reportfraud.ftc.gov.

CupyGift does not currently make decisions about customers based solely on automated processing that produce legal or similarly significant effects. Analytics and advertising tools may group interactions for measurement, but they are not used by CupyGift to make such contractual decisions.

The service is intended for adults who can enter into a contract. We do not knowingly collect personal information from children or knowingly invite children to place orders. Adults who provide a child's photograph or information for a gift must have the authority to do so and should provide only what is necessary.

This Notice may be updated when processing activities, providers or legal requirements change. A material change that affects an existing choice will be communicated through an appropriate notice or, where necessary, a request for renewed consent.