PRIVACY NOTICE FOR CUSTOMERS REGARDING THE PROCESSING OF PERSONAL DATA

This Privacy Notice has been prepared in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) to inform you about how your personal data is collected, processed, and shared by Kuzeyden İçecek Sanayi ve Ticaret Anonim Şirketi (“Kuzeyden”, “Company”, “we”, “our” or “us”).

1. Categories of Personal Data We Process

In connection with your use of the Kuzeyden Mobile Application, we process the following categories of personal data:

Identity Information: Name, surname, date of birth
Contact Information: Mobile phone number, email address
Visual Data: Profile picture
Health Data: Height, weight, daily step count, calories burned, sleep duration, and similar health-related information

2. Purpose and Legal Basis of Processing

Your personal data is processed in compliance with the legal bases outlined in Article 6 of the GDPR for the following purposes:

Personal Data	Purpose of Processing	Legal Basis
Identity Information, Contact Information, Visual Data	Management of user membership processes within the Kuzeyden Mobile Application.	Performance of a contract (Art. 6(1)(b) GDPR)
Identity Information, Contact Information, Visual Data	Execution of loyalty programs and related processes.	Performance of a contract (Art. 6(1)(b) GDPR)
Identity Information, Contact Information	Conducting marketing activities, promotions, and communication efforts.	Consent (Art. 6(1)(a) GDPR)
Identity Information, Contact Information	Performing customer satisfaction surveys and personalized marketing analysis.	Consent (Art. 6(1)(a) GDPR)
Health Data	Providing hydration recommendations based on health data (such as step count) if access is granted to Apple Health or similar health data providers.	Explicit consent (Art. 9(2)(a) GDPR)

3. Data Sharing and Recipients

We may share your personal data with third parties under the conditions set out in Articles 44-49 of the GDPR, including:

Personal Data	Purpose of Transfer	Recipient(s)
Identity Information, Contact Information, Visual Data	Execution of loyalty programs.	Third-party platforms where users choose to redeem their loyalty points.
Identity Information, Contact Information	Execution of marketing and promotional activities.	Business partners supporting customer relationship management and advertising services.
Identity Information, Contact Information	Compliance with legal obligations.	Regulatory authorities, courts, and law enforcement agencies.
Identity Information, Contact Information	Legal support services.	Law firms and legal consultants.

International Data Transfers: If we transfer your data outside the European Economic Area (EEA), we ensure that appropriate safeguards, such as Standard Contractual Clauses (SCCs) or adequacy decisions by the European Commission, are in place.

4. How We Collect Your Personal Data

Your personal data is collected through electronic means, including:

The membership forms you complete when registering for the Kuzeyden Mobile Application.
Health data providers such as Apple Health, if you grant access.

5. Your Rights Under GDPR

As a data subject, you have the following rights under Articles 12-22 of the GDPR:

Right of Access: Request confirmation as to whether your personal data is being processed and obtain access to it.
Right to Rectification: Request correction of inaccurate or incomplete personal data.
Right to Erasure (“Right to be Forgotten”): Request deletion of your personal data under certain conditions.
Right to Restriction of Processing: Request restriction of processing where data is inaccurate or no longer needed.
Right to Data Portability: Receive your data in a structured, machine-readable format and transmit it to another controller.
Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.
Right to Withdraw Consent: Withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
Right to Lodge a Complaint: File a complaint with the relevant Data Protection Authority (DPA) if you believe your data protection rights have been violated.

6. Contact Us

For any inquiries or to exercise your rights under the GDPR, you may contact us using the details below:

Data Controller: Kuzeyden İçecek Sanayi ve Ticaret Anonim Şirketi
Postal Address: Barbaros Mah. Begonya Sk. Nidakule Kuzey Ataşehir No: 3 İç Kapı No: 156 Ataşehir / İstanbul
Email: info@kuzeydensu.com
KEP Address: kuzeydeniceceksanayi@hs01.kep.tr

We will respond to your request within one month, as required by the GDPR. If additional time is needed, we will inform you accordingly.