1. Introduction

Aydın Kardeşler Gıda San. Tic. Ltd. Şti. (“Company”) attaches great importance to the protection of personal data and the privacy of private life. In this regard, the Company acts in accordance with the Turkish Personal Data Protection Law No. 6698 (“Law” or “KVKK”) and takes the necessary administrative and technical measures for the lawful processing and protection of personal data.

The Company does not consider the protection of personal data only as a legal obligation. Respect for individuals, privacy and data security forms the basis of our approach.

2. Purpose of the Policy

The purpose of this Policy is to inform data subjects about the principles adopted by the Company regarding the processing, storage, protection, transfer and destruction of personal data, and to explain the rights of data subjects under the applicable legislation.

3. Scope of the Policy

This Policy applies to customers, potential customers, website visitors and other natural persons who use or contact the services provided through Cini.com.tr.

The Policy covers personal data collected through the website www.cini.com.tr, social media channels, order and support lines, e-mail communications, return forms, membership transactions and other communication channels.

This Policy applies only to personal data relating to natural persons. It does not apply to legal entities as such.

4. Collection of Personal Data

Your personal data may be collected when you create a membership account, update your account information, fill out a form on our website, contact us through social media, purchase products or services, communicate with us by phone or e-mail, fill out a return form or visit our website.

Depending on the nature of your transaction, the following categories of personal data may be collected:

• Name and surname, e-mail address and telephone number,
• Delivery address, billing address and invoice information,
• Order information, previous order records, cart information and product details,
• Identity or tax information where required under applicable legislation,
• Financial information such as IBAN or account information where required for refund or payment processes,
• Order tracking numbers, shipment tracking information and cargo process records,
• Information submitted through contact forms, support requests and e-mail correspondence,
• Profile information shared through social media channels, where permitted by you,
• Voice recordings and communication records in calls made through the order and support line, where applicable,
• Return request information, including the returned product, reason for return, account holder information and contact details.

5. Personal Data Belonging to Third Parties

If you provide personal data belonging to another person, such as a delivery address, billing address, bank account information or information relating to a cardholder other than yourself, you undertake that you are authorized to share such information with us and that the relevant person has been informed where required.

6. Legal Grounds for Processing Personal Data

Personal data is processed in accordance with the applicable legislation and may be processed based on one or more of the following legal grounds:

• It is expressly provided for by law,
• It is necessary for the establishment or performance of a contract,
• It is necessary for the Company to fulfill its legal obligations,
• It is necessary for the establishment, exercise or protection of a right,
• The personal data has been made public by the data subject,
• It is necessary for the legitimate interests of the Company, provided that it does not harm the fundamental rights and freedoms of the data subject,
• The explicit consent of the data subject has been obtained, where required.

7. Purposes of Processing Personal Data

The Company processes personal data in accordance with the principles of lawfulness, fairness, accuracy, being up to date where necessary, purpose limitation, data minimization and storage limitation.

Your personal data may be processed for the following purposes:

• Carrying out sales processes for goods and services,
• Preparing, delivering and tracking orders,
• Providing after-sales support services,
• Managing customer relations and customer satisfaction processes,
• Carrying out communication activities,
• Managing logistics, shipment and return processes,
• Carrying out finance and accounting transactions,
• Executing contract processes,
• Responding to requests, complaints and support applications,
• Conducting marketing, campaign and promotional activities where permitted by law,
• Ensuring that activities are carried out in compliance with applicable legislation,
• Providing information to authorized public institutions and organizations where legally required,
• Ensuring information security and improving service quality.

8. Transfer of Personal Data

Your personal data may be transferred, limited to the purposes of processing and in accordance with Articles 8 and 9 of the Law, to the following persons and organizations where necessary:

• Business partners and service providers,
• Suppliers and technical service providers,
• Cargo and logistics companies,
• Banks, payment service providers and financial institutions,
• Accounting, audit, insurance and legal service providers,
• Authorized public institutions and organizations, where legally required,
• Other real persons or private legal entities where transfer is necessary for the performance of the relevant service.

9. Storage and Destruction of Personal Data

Personal data is stored for the periods required by the applicable legislation or, where no specific legal period is provided, for as long as necessary for the purposes for which it is processed.

When the reasons requiring the processing of personal data cease to exist, the relevant personal data is deleted, destroyed or anonymized in accordance with the applicable legislation and the Company’s retention and destruction procedures.

Deletion means making personal data inaccessible and unusable for relevant users. Destruction means making personal data inaccessible, unrecoverable and unusable by anyone. Anonymization means rendering personal data impossible to associate with an identified or identifiable natural person.

10. Rights of the Data Subject

Pursuant to Article 11 of the Law, data subjects have the following rights regarding their personal data:

• To learn whether personal data is being processed,
• To request information if personal data has been processed,
• To learn the purpose of processing and whether the data is used in accordance with that purpose,
• To know the third parties to whom personal data is transferred domestically or abroad,
• To request correction if personal data is incomplete or incorrectly processed,
• To request deletion or destruction of personal data under the conditions set out in the Law,
• To request notification of correction, deletion or destruction processes to third parties to whom the data has been transferred,
• To object to any result arising against the person through analysis of processed data exclusively by automated systems,
• To request compensation in case of damage due to unlawful processing of personal data.

11. Application Procedure

Requests and applications regarding the implementation of the Law may be submitted in writing to the following address:

Aydın Kardeşler Gıda San. Tic. Ltd. Şti.
Mustafa Kemal Paşa Mah. Hoca Ahmet Yesevi Sok. No:15 İznik / Bursa / Türkiye

Applications must include the applicant’s name and surname, signature if the application is made in writing, identification information, notification address, contact details if available, and the subject of the request.

The Company will finalize the requests as soon as possible and within thirty days at the latest, depending on the nature of the request. If the process requires an additional cost, the fee determined by the relevant authority may be charged. If the request is rejected, the response is found insufficient, or no response is provided within the legal period, the data subject may exercise the right to lodge a complaint with the competent authority within the periods specified by law.

12. Contact

For questions regarding this Policy or for requests concerning your personal data, you may contact us at info@cini.com.tr.