Introduction
Aperatif Gıda Sanayi ve Ticaret Limited Şirketi respects your privacy and is committed to protecting your personal data. This Privacy Policy explains what personal data we collect through aperatifgida.com (the "Website"), why we collect it, how we use and protect it, and what rights you have.
It is prepared in accordance with the Personal Data Protection Law No. 6698 ("KVKK"), the secondary legislation issued under it, and the decisions of the Personal Data Protection Board.
We keep our data processing deliberately limited. We collect personal data only where you choose to contact us, we do not track visitors, we do not profile you, we do not send marketing communications, and we do not sell or rent personal data to anyone.
Data controller
For the purposes of the KVKK, the data controller is:
Company: Aperatif Gıda Sanayi ve Ticaret Limited Şirketi
Registered address: Oruç Reis Mah. Tekstilkent Cad. Ara Blok No: 10 AC/Z 18, Esenler / İstanbul, Türkiye
Trade registry: İstanbul Ticaret Sicili Müdürlüğü, No. 931047
MERSİS number: 0071043187100013
Telephone: +90 532 158 12 81
General email: info@aperatifgida.com
Data protection email: privacy@aperatifgida.com
Personal data we collect
3.1. Data you provide through the quotation form
When you submit an enquiry or request a quotation through the form on the Website, we collect the following, all of which are required in order for us to respond:
Full name, which is identity data (kimlik verisi) under the KVKK.
Email address and phone number, which are contact data (iletişim verisi).
The content of your message, which is transaction and customer-transaction data (işlem ve müşteri işlem verisi).
The message field is free text. Please include only the information necessary for your enquiry, and do not submit special categories of personal data, such as health, biometric or religious data, or the personal data of third parties without a lawful basis for doing so.
Form submissions are delivered to our email inbox. We do not store them in any separate customer database or marketing system.
3.2. Data you provide by contacting us directly
If you contact us by email, telephone or post, we collect the contact details and the content of your communication.
3.3. Technical data recorded by our hosting provider
When you visit the Website, our hosting provider records standard server log data, including IP address, browser type, operating system, pages requested, and the date and time of the request. This is a normal function of operating a web server and is used only to keep the Website running securely and reliably, including protection against automated abuse and spam. We do not use this data to identify or profile individual visitors.
We do not use analytics tools, advertising pixels, tracking technologies or any similar tools on the Website.
3.4. Data we do not collect
We do not knowingly collect special categories of personal data through the Website. We do not collect payment card details through the Website. We do not build visitor profiles, and we do not carry out automated decision-making or profiling of any kind.
Purposes of processing
We process personal data for the following purposes:
(a) receiving, evaluating and responding to your enquiry or quotation request;
(b) preparing and communicating quotations, product information and availability;
(c) establishing and managing a commercial relationship, including negotiating and performing supply arrangements;
(d) carrying out customer relationship management and business communication connected with your enquiry;
(e) maintaining records of business communications and transactions;
(f) fulfilling our legal, tax, accounting and regulatory obligations;
(g) establishing, exercising or defending legal claims;
(h) ensuring the security and reliable operation of the Website and of our information systems, and preventing fraud and misuse.
We do not use your personal data for marketing purposes.
Legal grounds for processing
We rely on the following legal grounds under Article 5 of the KVKK.
Article 5/2(c), processing necessary for the conclusion or performance of a contract. This covers handling your enquiry, issuing quotations, and establishing and performing a supply relationship.
Article 5/2(ç), compliance with a legal obligation. This covers meeting tax, accounting, commercial and record-keeping obligations under Turkish law.
Article 5/2(e), establishment, exercise or protection of a right. This covers retaining records that may be needed in connection with a legal claim.
Article 5/2(f), legitimate interests of the data controller, provided this does not harm your fundamental rights and freedoms. This covers managing our business relationship with you, keeping records of enquiries, and maintaining the security and integrity of the Website.
We do not currently carry out any processing that relies on your explicit consent (açık rıza). If that changes, we will obtain your consent separately and beforehand, and this Policy will be updated.
How we collect personal data
Personal data is collected by automated and partly automated means through the Website, its enquiry form and its hosting infrastructure, and by non-automated means where you contact us by email, telephone, post or in person.
Disclosure and transfer of personal data
We do not sell, rent or trade personal data. We may disclose personal data in the following circumstances, in each case limited to what is necessary and in compliance with Articles 8 and 9 of the KVKK.
Website hosting. The Website is built and hosted on Framer (Framer B.V., Netherlands), whose services run on Amazon Web Services infrastructure located in the United States, with content delivered through a global edge network. Framer processes server log data and transmits enquiry-form submissions.
Domain services. Our domain is registered through GoDaddy (United States), which processes domain registration and DNS data.
Email. We use Google's email services (Google LLC, United States, and its affiliates), which process the content of enquiry emails and our correspondence with you.
Professional advisers. Our accountants, auditors and legal advisers, where necessary and subject to confidentiality.
Business partners. Where necessary to respond to your enquiry or fulfil an order, including logistics and customs service providers.
Public authorities. Courts, tax authorities, regulatory and law enforcement bodies, where required by law or a lawful request.
Business transfers. In the context of a merger, acquisition or restructuring, subject to appropriate safeguards.
7.1. Transfers abroad
Our hosting, domain and email providers are established outside Türkiye and process data on infrastructure located principally in the United States and the European Union. Personal data submitted through the Website is therefore transferred abroad. In addition, where an enquiry requires us to contact a supplier abroad, your contact details and the substance of your enquiry may be shared with that supplier.
Such transfers are made in accordance with Article 9 of the KVKK, on the basis of one of the following:
(a) a decision of the Personal Data Protection Board that the destination country, sector or international organisation offers an adequate level of protection;
(b) in the absence of an adequacy decision, an appropriate safeguard, such as standard contractual clauses notified to the Board, binding corporate rules, or a written undertaking authorised by the Board;
(c) where neither of the above applies, one of the exceptional grounds set out in Article 9/6 of the KVKK, including your explicit consent for the specific transfer.
Retention
We retain personal data only for as long as necessary for the purposes described above, and thereafter for the periods required by law. We do not keep personal data indefinitely.
Enquiries and quotation requests that do not lead to a business relationship are kept for 2 years from the date of last contact.
Correspondence and records relating to an established business relationship are kept for 10 years from the end of the relationship, in line with the general statute of limitations under Article 146 of the Turkish Code of Obligations.
Commercial books, invoices and accounting records are kept for 10 years, in line with Article 82 of the Turkish Commercial Code. Article 253 of the Tax Procedure Law requires 5 years, so the longer period applies.
Website server logs are kept for 1 year for security and abuse prevention.
At the end of the applicable period, personal data is deleted, destroyed or anonymised in accordance with the Regulation on the Deletion, Destruction or Anonymisation of Personal Data.
Cookies
The Website uses only strictly necessary cookies. These are required for the Website to function and to remain secure, for example to maintain session integrity, to keep the enquiry form working correctly and free of spam, and to remember your language selection.
Strictly necessary cookies are used on the basis of our legitimate interest under Article 5/2(f) of the KVKK and do not require your consent.
We do not use analytics cookies, advertising cookies, social media tracking pixels or any other non-essential tracking technology, and we do not share information about your visit with advertising networks or data brokers.
You can manage or delete cookies through your browser settings. Please note that disabling strictly necessary cookies may prevent parts of the Website from working properly.
Data security
We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration and disclosure, taking into account the nature of the data and the risks involved. These measures include encrypted transmission of form data (TLS), encryption of stored data by our service providers, access controls limiting access to authorised personnel on a need-to-know basis, confidentiality obligations for staff and service providers, and periodic review of our security measures.
No transmission over the internet can be guaranteed to be completely secure. In the event of a personal data breach, we will act in accordance with Article 12 of the KVKK, including notifying the Personal Data Protection Board and affected individuals within the periods required.
Your rights
Under Article 11 of the KVKK, you have the right to:
(a) learn whether your personal data is being processed;
(b) request information if your personal data has been processed;
(c) learn the purpose of processing and whether the data is used in accordance with that purpose;
(ç) know the third parties in Türkiye or abroad to whom your personal data is transferred;
(d) request correction of incomplete or inaccurate data;
(e) request deletion or destruction of your personal data within the conditions set out in Article 7 of the KVKK;
(f) request that any correction, deletion or destruction be notified to third parties to whom the data was transferred;
(g) object to a result arising against you from analysis of your data exclusively by automated systems;
(ğ) claim compensation for damage arising from unlawful processing of your personal data.
How to exercise your rights
You may submit a request under Article 11 by using the methods set out in the Communiqué on the Procedures and Principles of Application to the Data Controller:
(a) in writing, delivered in person or by notary, to Oruç Reis Mah. Tekstilkent Cad. Ara Blok No: 10 AC/Z 18, Esenler / İstanbul, Türkiye;
(b) by secure electronic signature or mobile signature;
(c) by email from an address previously notified to us and registered in our systems, sent to privacy@aperatifgida.com.
Your request should state your name, surname and signature, your Turkish identity number or, for foreign nationals, your nationality, passport number or identity number, your address for notification, and the subject of your request, together with any supporting information or documents.
We will respond free of charge and as soon as possible, and in any event within thirty days of receipt. Where the response requires additional cost, we may charge the fee set out in the tariff published by the Personal Data Protection Board.
If your request is rejected, our response is unsatisfactory, or we fail to respond in time, you may lodge a complaint with the Personal Data Protection Board within thirty days of becoming aware of our response and in any event within sixty days of the date of your application.
Commercial electronic messages
We do not send marketing or promotional electronic messages. Submitting a quotation request will not result in you being added to any mailing list.
We will contact you only in response to your enquiry and in connection with any resulting business relationship.
Should we introduce marketing communications in future, we will do so only in accordance with Law No. 6563 on the Regulation of Electronic Commerce, with prior consent registered in the Message Management System (İleti Yönetim Sistemi, İYS), and with an opt-out available in every message.
Children
The Website is directed at businesses and is not intended for children. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will take appropriate steps to delete it.
Changes to this Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. The updated version takes effect when published on the Website, and the "Last updated" date will be revised. Where a change is significant, we will take reasonable steps to bring it to your attention.
Contact
For any question about this Privacy Policy or about how we handle personal data:
Aperatif Gıda Sanayi ve Ticaret Limited Şirketi
Oruç Reis Mah. Tekstilkent Cad. Ara Blok No: 10 AC/Z 18, Esenler / İstanbul, Türkiye
Email: privacy@aperatifgida.com
Telephone: +90 532 158 12 81