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Kitcie Personal Data Protection and Processing Disclosure Text

Privacy notice under Turkish Law No. 6698 (KVKK).

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Version 2.0 · Last updated: August 29, 2026

1. Data Controller

This Disclosure Text has been prepared under Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”) regarding the processing of your personal data.

The data controller responsible for operating the Kitcie platform is:

TAVAKTECH LTD

Company Number: 16563260

Registered Office: Office 106, 9 Brewers Lane, Richmond, Surrey, England TW9 1HH

Kitcie processes your personal data under the Kitcie brand mobile app, website, and digital platform services in compliance with KVKK and related legislation.

If Kitcie services in Turkey are additionally carried out through a separate company, branch, or representative, relevant structure and contact details will be added to this text.

2. About Kitcie

Kitcie is a mobile app and web platform that connects businesses with end users, enabling users to discover businesses by location or food/product search, view menus, and read user reviews and ratings.

Under Kitcie's current service model, the Platform does not:

• process reservations;

• accept orders or pre-orders;

• collect payments from users;

• transfer user payments to businesses;

• charge businesses sales or transaction commission.

Kitcie is not a party to product or service purchases between users and businesses that occur outside the Platform under the current model.

3. Personal Data Processed

Depending on your use of Kitcie services and your relationship with the Platform, the following personal data categories may be processed:

3.1. Identity Information

• First name

• Last name

• Username

• Business authorized person name

• Account information

3.2. Contact Information

• Email address

• Phone number

• Communication preferences

3.3. Business Information

For business users;

• Trade name, business name, address, contact details, tax and commercial registration details, authorized person details, business category, menu and product information, and other information uploaded by the business may be processed.

3.4. Usage and Security Information

• IP address, device information, operating system, browser information, app usage data, session data, logs, timestamps, authentication and security records

3.5. Location Information

With user permission or use of relevant features: device location, approximate location, search location, selected region or location may be processed. Device OS permission may also be required.

3.6. Visual and Content Information

If uploaded: profile photo, business photos, menu photos, user reviews, and other user-generated content may be processed.

3.7. Marketing and Preference Information

Where required legal conditions exist: commercial communication preferences, notification preferences, campaign and marketing preferences, and Platform usage preferences may be processed.

3.8. Special Categories of Personal Data

Under Kitcie's current service model, processing of special categories of personal data is not intended.

Users and businesses should not share special category personal data through reviews, profiles, or other content.

4. Collection Methods

Personal data may be collected automatically or partially automatically via the Kitcie mobile app, website, membership forms, business profile screens, search and usage activities, reviews and ratings, communication channels, technical systems and logs, devices and browsers, and cookies and similar technologies.

Personal data may also be obtained from third parties, public institutions, or publicly available sources where permitted by law.

5. Processing Purposes

Personal data may be processed for the following purposes:

5.1. Providing Platform Services

• Creating and managing user and business accounts

• Providing Platform services, discovery, search, menu and business information display, and improving user experience

5.2. Security and Operations

• Account security, preventing unauthorized access, fraud and abuse detection, technical issue resolution, system security, and cybersecurity activities

5.3. User Content and Interaction

• Publishing reviews and ratings, displaying user evaluations, assessing content compliance, and evaluating unlawful or abusive reports

5.4. Legal and Administrative Obligations

• Fulfilling legal obligations, responding to authorized public institutions, handling disputes and complaints, and establishing, exercising, or protecting rights

5.5. Platform Development

• Performance analysis, user experience improvement, new feature development, technical and statistical analysis, error and performance analysis

5.6. Marketing and Commercial Communication

Where required legal conditions exist, personal data may be processed for campaigns, marketing, personalized content and recommendations, and communication based on user preferences. Separate commercial electronic message consent mechanisms apply where required by law.

6. Legal Bases for Processing

Personal data may be processed based on one or more conditions under KVKK Article 5, including: explicit provision in law; direct relation to contract establishment or performance; legal obligation of the data controller; establishment, exercise, or protection of rights; legitimate interests of the data controller without harming fundamental rights; and explicit consent of the data subject.

Explicit consent is not used as a general legal basis where another processing condition already applies.

7. Recipients of Personal Data

Personal data may be transferred, limited to processing purposes and where required legal conditions exist, to Kitcie service providers, IT providers, hosting providers, software and infrastructure providers, security providers, analytics providers, professional advisors, authorized public institutions, and legally authorized private persons.

User reviews and ratings may be published in a manner visible to other users and Platform visitors depending on their nature.

8. Publication of Business Information

Business information uploaded or provided for public display (name, address, location, hours, menu, products, prices, photos, contact details, and other promotional information) may be shown to users on the Platform.

Personal data of business authorized persons is assessed separately based on nature and purpose.

9. User Reviews and Ratings

Reviews and ratings created on the Platform may be accessible to other users and the relevant business due to the nature of the service.

Users must not share third-party personal data or unlawful content when uploading content.

Kitcie evaluates applications regarding unlawful content or personality rights violations and may take necessary actions under applicable law.

10. Cross-Border Transfer of Personal Data

Because part of Kitcie's infrastructure may be hosted on servers or service providers in the United Kingdom, personal data processed within the Platform may be transferred to or stored on systems abroad.

Cross-border transfers are carried out in compliance with KVKK Article 9 and the Regulation on Procedures and Principles regarding Transfer of Personal Data Abroad.

Adequacy decisions, appropriate safeguards, or exceptional transfer conditions are evaluated. Standard contracts published by the Personal Data Protection Authority may be used where required.

The legal mechanism for cross-border transfer will be determined once Kitcie's servers and service providers are finalized.

11. Cookies and Similar Technologies

Kitcie may use mandatory cookies, functional cookies, performance and analytics technologies, and optional marketing technologies on its website and mobile app.

Detailed information is provided in the Kitcie Cookie Policy.

12. Retention Period

Personal data is retained for the period required by processing purposes and applicable legal retention periods, considering legal obligations, limitation periods, whether the processing purpose continues, and Platform security and technical requirements.

When the processing purpose ceases and no other legal basis for retention exists, personal data is deleted, destroyed, or anonymized in compliance with KVKK.

13. Data Security

Kitcie seeks to take necessary technical and administrative measures to prevent unlawful processing and access and to ensure retention of personal data, including access authorization, account security, technical access controls, logging, security monitoring, backup, and system security.

14. Data Subject Rights Under KVKK

Under KVKK Article 11, data subjects may:

a) learn whether personal data is processed;

b) request information if processed;

c) learn the purpose and whether use is appropriate;

ç) know third parties to whom data is transferred domestically or abroad;

d) request correction of incomplete or inaccurate data;

e) request deletion or destruction under KVKK conditions;

f) request notification of correction/deletion to third parties;

g) object to adverse results from solely automated analysis;

ğ) claim compensation for damage due to unlawful processing.

15. Application Method

You may submit KVKK requests via:

Email: destek@kitcie.app

Postal Address: Office 106, 9 Brewers Lane, Richmond, Surrey, England TW9 1HH

Registered Electronic Mail (KEP): Not yet assigned.

or other methods prescribed under KVKK and secondary legislation.

Applications are evaluated under applicable procedures and principles.

16. Updates

Kitcie may update this Disclosure Text due to legislative changes, changes in the Platform's technical or commercial structure, or changes in data processing activities.

The current text is published on Kitcie's website and/or mobile app.

Contact

Questions: destek@kitcie.app.

Kitcie Personal Data Protection and Processing Disclosure Text — Kitcie