Personal Data Processing Policy
This Policy describes how BRAZEL (hereinafter “we”, “the Company”) collects, uses, stores, and protects the personal data of users of the brazel.az website, the @Brazel_bot Telegram bot, and the Company’s WhatsApp Business channel. By using our services, you confirm your acceptance of this Policy.
1. Data controller
The personal-data controller is R.R. Bekeshev, VÖEN 1507656912, registered address: 188 Murtuza Mukhtarov str., Baku, AZ1065, Republic of Azerbaijan. Contact email for data-processing requests: privacy@brazel.az.
2. What data we collect
The data collected depends on which features of the site you use.
- Identification data: first name, last name, phone number (in international E.164 format), Telegram username, and the numeric Telegram account ID.
- Body measurements for the size calculator: underbust, standing bust, and leaning bust (in cm) — entered voluntarily to calculate bra size.
- Purchase data: order history, selected products, sizes, prices.
- Technical data: IP address (hashed), device type, browser, interaction timestamps.
- WhatsApp data: when contacting us via WhatsApp Business — your WhatsApp number, message metadata, and conversation content within the scope of support.
3. Purposes and legal bases
- Performance of the sale contract (GDPR-equivalent Art. 6(1)(b)): processing purchases and reservations, handling requests, purchase-related communication.
- User consent (Art. 6(1)(a)): size calculation, back-in-stock notifications, marketing communication.
- Legitimate interests (Art. 6(1)(f)): protection from fraud and automated attacks, analytics to improve the service.
- Legal compliance: retention of accounting and tax data for the required periods.
4. Categories of data recipients
We engage third-party service providers acting as data processors on our behalf and bound by confidentiality agreements:
- Cloud hosting provider (US jurisdiction) — site hosting, CDN, temporary storage of session data.
- Cloud data-management platform (US jurisdiction) — storage of the product catalog, orders, and customer profile.
- Telegram instant-messaging platform (Telegram FZ LLC, UAE) — authentication via the Telegram Login Widget, service notifications via @Brazel_bot, support communication.
- WhatsApp Business Platform (Meta Platforms, Inc., USA) — processing messages in the Company’s WhatsApp channel.
- Payment services — processing payments via issued links.
We do not sell personal data to third parties. Data may be disclosed to government authorities only upon lawful request.
5. International data transfers
Some of our processors are located outside the Republic of Azerbaijan (in particular, in the USA). Data is transferred on the basis of standard contractual clauses and other mechanisms ensuring an adequate level of protection under applicable law.
6. Retention periods
- Customer-profile data and order history — while the account is active and thereafter for the periods required by Azerbaijani tax law.
- Body measurements from the calculator — while the account is active or until the user withdraws consent.
- Interaction logs (IP, technical events) — 90 days.
- WhatsApp messages — up to 2 years after the last contact, then anonymized.
7. WhatsApp Business — special terms
We use Meta’s WhatsApp Business Platform to communicate with customers. You will receive messages from us only in the following cases:
- You initiated a conversation with us via WhatsApp.
- You gave explicit consent to receive WhatsApp notifications when placing an order or registering.
- Notifications related to your booking: confirmation, fitting-appointment reminders.
Marketing messages are sent only after your explicit opt-in. You can stop receiving messages at any time by sending us the word “STOP” in the WhatsApp chat — we will stop the mailings within 24 hours. Messages required by law or related to an active order will continue to be sent.
WhatsApp message processing is also governed by the WhatsApp Privacy Policy and the WhatsApp Business Messaging Policy.
8. Cookies and similar technologies
We use strictly necessary cookies for the site to function (session, Telegram authorization, cart), as well as browser local storage (localStorage) to remember your preferences (size, favorite products). No third-party tracking / marketing cookies are used on the site.
9. Data protection
We apply technical and organizational security measures: HTTPS for all connections, HMAC-signed session cookies, storage of secrets in protected environment variables, a limited number of employees with data access, and regular monitoring of suspicious activity.
10. Your rights
In accordance with the applicable law of the Republic of Azerbaijan and international data-protection standards, you have the following rights:
- Access: obtain a copy of your data and information about its processing.
- Rectification: request correction of inaccurate or incomplete data.
- Erasure: request deletion of your data where there is no lawful basis to retain it.
- Restriction of processing in certain cases.
- Withdrawal of consent at any time without giving reasons.
- Data portability: receive your data in a machine-readable format.
- Objection to processing based on our legitimate interests.
To exercise any of these rights, send a request to privacy@brazel.az — we will respond within 30 days.
11. Age of users
The BRAZEL site and services are intended for persons over 18. We do not knowingly collect data from minors. If you know that a minor has provided us with data, please contact us to delete it.
12. Changes to the Policy
We may update this Policy when the data collected, the purposes of processing, or applicable law change. The current version is always available at brazel.az/policy/privacy. For material changes, we will notify you by email or via the site.
13. Contacts
For any questions related to the processing of your data:
- Email: privacy@brazel.az
- Telegram: @Brazel_bot
- WhatsApp: +994 10 511 76 77