1. GENERAL INFORMATION

GİNUT attaches importance to the privacy of its customers, members and visitors of www.ginut.com.tr, as well as to the protection of their personal data.

This Privacy and Personal Data Protection Policy explains how personal data obtained during the use of our website, creation of memberships, placement of orders, payment and delivery processes, communication with customer services, and use of our other services is processed and protected.

Your personal data is processed and protected in accordance with applicable legislation, particularly Law No. 6698 on the Protection of Personal Data (“KVKK”).

2. DATA CONTROLLER

For the purposes of KVKK, the data controller responsible for your personal data is:

GİNUT Naturally Better Giresun Origin

Address: Teyyaredüzü Mahallesi, Yeşim Sokak No:33, 28200 Merkez/GİRESUN, TÜRKİYE
Telephone: +90 546 506 55 45
E-mail: market@ginut.com.tr
Website: www.ginut.com.tr

3. PERSONAL DATA THAT MAY BE PROCESSED

Depending on how you use our website and services, the following categories of personal data may be processed:

Identity information, such as name and surname,
Contact information, such as telephone number, e-mail address, delivery address and billing address,
Customer transaction information, including orders, purchase history, returns and requests,
Financial transaction information, including payment method and information required for payment transactions,
Information required for invoicing and tax-related transactions,
Website usage information, including IP address, session and transaction records, device information and browser information,
Requests, suggestions and complaints submitted within the scope of customer services,
Other information required to fulfill legal obligations.

As a general principle, personal data that is not necessary for providing our services will not be requested, and personal data will be processed in a manner that is relevant, limited and proportionate to the purposes for which it is processed.

4. PURPOSES OF PROCESSING PERSONAL DATA

Depending on the nature of the relevant processing activity, your personal data may be processed for the following purposes:

Managing membership and user account processes,
Receiving and processing orders,
Establishing and performing sales agreements,
Processing payments,
Issuing invoices,
Preparing, dispatching and delivering products,
Managing returns, withdrawals, exchanges and customer requests,
Providing customer service,
Evaluating requests, suggestions and complaints,
Ensuring transaction and system security,
Preventing fraud, abuse and unauthorized transactions,
Improving website performance and user experience,
Fulfilling legal and commercial obligations,
Responding to lawful requests from authorized public institutions and authorities,
Establishing, exercising or protecting legal rights.

Advertising, campaigns, promotions and marketing communications are carried out in accordance with the preferences and consents of the relevant person to the extent required under applicable legislation.

5. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

Your personal data is processed on the basis of the legal grounds specified under KVKK, depending on the relevant processing activity.

In particular, personal data may be processed where:

processing is directly related to the establishment or performance of a contract,
processing is necessary for the Company to fulfill its legal obligations,
processing is necessary for the establishment, exercise or protection of a right,
processing is necessary for the legitimate interests of the Company, provided that the fundamental rights and freedoms of the data subject are not harmed,
processing is expressly provided for by law.

Where explicit consent is required under applicable legislation, your personal data will be processed based on your explicit consent.

6. METHODS OF COLLECTING PERSONAL DATA

Your personal data may be collected electronically or, where necessary, physically through:

www.ginut.com.tr,
membership and order forms,
payment and delivery processes,
e-mail and telephone communications,
customer service communication channels,
cookies and similar technologies,
transactions carried out with courier, payment and other service providers.

7. TRANSFER OF PERSONAL DATA

Your personal data is not sold to third parties for commercial purposes.

However, where necessary for the provision of our services and fulfillment of our legal obligations, your personal data may be transferred, in accordance with applicable legislation and only to the extent necessary, to:

courier and logistics companies,
banks, payment institutions and financial service providers,
information technology, hosting and technical infrastructure service providers,
accounting and financial service providers,
legal and professional advisers,
authorized public institutions and authorities,
other natural or legal persons authorized by law.

Any transfer of personal data is limited to the information necessary for providing the relevant service or fulfilling applicable legal obligations.

8. PAYMENT AND CREDIT CARD SECURITY

Payments made through the website may be processed through the secure payment infrastructure of the relevant bank and/or authorized payment service provider.

Where credit or debit card information is processed through the secure infrastructure of a payment service provider, Halis Fındık only uses the transaction information necessary to complete the order and payment process.

Where card information is stored or processed, such processing is carried out within the security standards and legal framework applicable to the relevant payment service provider.

Necessary technical and administrative measures are taken to protect the security of customers' payment information.

9. COOKIES AND WEBSITE USAGE DATA

Cookies and similar technologies may be used on www.ginut.com.tr to ensure that the website functions properly, remember user preferences, maintain security, analyze visitor activity and improve the overall user experience.

The use of non-essential cookies is subject to user preferences and consent where required under applicable legislation.

Detailed information regarding the types of cookies used, their purposes, retention periods and how cookie preferences can be managed is provided in our Cookie Policy.

10. COMMERCIAL ELECTRONIC COMMUNICATIONS

Marketing communications regarding campaigns, discounts, new products, promotions and similar offers are sent in accordance with the permissions and communication preferences required under applicable legislation.

Users may change their marketing communication preferences by using the unsubscribe or communication preference options provided in commercial electronic messages.

Withdrawal of consent for marketing communications does not prevent the Company from sending service-related messages necessary for order, payment, delivery, customer service or similar transactional purposes.

11. RETENTION OF PERSONAL DATA

Your personal data is retained for the periods prescribed under applicable legislation or for as long as necessary for the purposes for which it is processed.

When the applicable retention period expires or the reasons requiring the processing of personal data cease to exist, the relevant personal data is deleted, destroyed or anonymized in accordance with applicable legislation.

12. DATA SECURITY

Halis Fındık takes appropriate technical and administrative measures to:

prevent unlawful processing of personal data,
prevent unauthorized access to personal data,
ensure the secure storage of personal data.

These measures may include access authorization controls, system security measures, data access restrictions and other appropriate safeguards depending on the nature of the data processed.

However, no method of data transmission over the internet can be guaranteed to be completely risk-free.

13. YOUR RIGHTS REGARDING PERSONAL DATA

Under Article 11 of KVKK, and subject to the conditions set out in applicable legislation, you have the right to:

learn whether your personal data is being processed,
request information if your personal data has been processed,
learn the purpose of processing your personal data and whether it is being used in accordance with that purpose,
learn the third parties to whom your personal data has been transferred,
request correction of incomplete or inaccurate personal data,
request deletion or destruction of personal data where the conditions prescribed by law are met,
request notification of correction, deletion or destruction operations to third parties to whom the personal data has been transferred,
object to a result arising against you as a result of the analysis of personal data exclusively by automated systems, where permitted by law,
request compensation for damages arising from the unlawful processing of personal data.

14. APPLICATIONS AND CONTACT

You may submit requests regarding your personal data in accordance with KVKK and applicable legislation using the following contact details:

Özkaya Gıda Turizm Elektronik Sanayi Ticaret Ltd. Şti.
Teyyaredüzü Mahallesi, Yeşim Sokak No:33, 28200 Merkez/GİRESUN, TÜRKİYE

Telephone: +90 454 215 00 01
E-mail: market@ginut.com.tr
Website: www.ginut.com.tr

Applications will be reviewed and concluded within the periods prescribed under applicable legislation, depending on the nature of the request.

15. CHANGES TO THIS POLICY

This Privacy and Personal Data Protection Policy may be updated due to changes in legislation, updates to the website infrastructure, or changes in the Company's personal data processing activities.

The current version of this Policy becomes effective on the date it is published on www.ginut.com.tr.

Last Updated: August 2026

Privacy Policy