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Privacy Notice on the Processing of Personal Data

Relating to the use of the Su iste Artificial Intelligence Assistant (“Su iste AI”).

Contents

  1. Artificial Intelligence Disclosure and Important Usage Notice
  2. Data Controller
  3. Scope of the Privacy Notice and How the Service Works
  4. Categories of Personal Data Processed
  5. Purposes and Legal Grounds for Processing
  6. Method of Collection of Personal Data
  7. Parties to Whom Personal Data May Be Transferred
  8. Transfer of Personal Data Abroad
  9. Data Retention Periods
  10. AI-Assisted Processing and Automated Decisions
  11. Data Security
  12. Your Rights Under the KVKK
  13. Exercising Your Rights and Application Procedure
  14. Changes to the Privacy Notice

1. Artificial Intelligence Disclosure and Important Usage Notice

In this chat area, you are communicating not with a real person, but with an AI-powered assistant called “Su iste AI.” Su uses artificial intelligence technologies to provide information about products, prices, promotions, stock availability, delivery areas, existing orders, and support requests. Where necessary, your request may be referred to the authorized support team.

Responses generated by artificial intelligence may occasionally contain incomplete, inaccurate, or outdated information. Therefore, we recommend verifying information that is important to your orders and transactions through the relevant service channels.

For your security, please do not share passwords, one-time verification codes, bank or credit card information, Turkish Republic identification numbers, identity document information, health information, or any other personal data that is not necessary for your request in the chat area.

2. Data Controller

Pursuant to the Turkish Personal Data Protection Law No. 6698 (“KVKK”), the following legal entity acts as the data controller with respect to personal data processed during your use of the Su Artificial Intelligence Assistant:

  • Trade Name: SU ISTE PERAKENDE VE LOJISTIK LIMITED SIRKETI
  • Address: Bahçeşehir 2. Kısım Mah. Şelale Cad. Akın Sok. No: 1K Başakşehir/Istanbul, Türkiye
  • KVKK Contact Email: info@suiste.com
  • Telephone: +90 533 329 6050

In this Notice, SU ISTE PERAKENDE VE LOJISTIK LIMITED SIRKETI shall hereinafter be referred to as the “Company.” “Su iste” refers to the service, while “Su” refers to the AI-powered assistant.

3. Scope of the Privacy Notice and How the Service Works

This Privacy Notice covers personal data processing activities carried out during the use of the Su iste Artificial Intelligence Assistant through the Su iste website and iOS/Android mobile applications.

Messages you share with Su and information necessary to respond to your request are processed through artificial intelligence infrastructure in order to understand your questions and generate appropriate responses. In this context, technical and artificial intelligence services provided by Cloudflare and OpenAI are used.

Where logged-in users request information regarding products, deliveries, or existing orders, the user, dealer, or order information necessary to fulfil the request may be processed.

If you request that the support team contact you, your telephone number may be used solely for the purpose of fulfilling this request. Contact information obtained for this purpose will not be used for marketing purposes unless separate consent has been provided.

4. Categories of Personal Data Processed

Depending on how you use Su and the nature of your request, the following categories of personal data may be processed:

  • Conversation and support data: Messages, questions, requests, complaints, assistant responses, and information relating to the support process that you share with Su iste AI.
  • Account and transaction data: Login and session information, as well as user, dealer, and existing order information necessary to fulfil your request.
  • Contact data: Your telephone number and communication preference if you request that the support team contact you.
  • Location data: Province/district information provided by you for the purpose of determining the delivery area or the dealer serving you, as well as location information obtained from your device where you have granted permission.
  • Technical and security data: Technical information necessary for the operation and security of the service, such as IP address, session information, date/time, device or platform information, application/widget version, and error and performance logs.
  • Usage and feedback data: Events relating to chatbot usage, as well as ratings, satisfaction information, and feedback provided by you.
  • Inference and classification data: Limited classifications generated by the system relating to the subject or purpose of the conversation, whether the request has been resolved, sentiment, and response quality.

Su is not designed to collect passwords, bank or credit card information, Turkish Republic identification numbers, identity document information, or special categories of personal data. Please do not share such information in the chat area unless it is necessary for your request.

5. Purposes and Legal Grounds for Processing

Your personal data may be processed for the following purposes and on the legal grounds specified under the KVKK in connection with your use of the Su iste Artificial Intelligence Assistant:

  • Responding to your questions and providing information about the service: Conversation, account, transaction, and, where necessary, location data may be processed in order to provide information and support regarding products, prices, promotions, stock availability, deliveries, and existing orders. Such processing is based on the legal ground that it is directly related to the establishment or performance of a contract. Necessary data may be transferred to the relevant service or dealer units and technical service providers.
  • Fulfilling callback and support requests: If requested by you, your contact and support data may be processed for the purpose of contacting you and managing the support process. Such processing is based on the legal ground that it is directly related to the establishment or performance of a contract, and necessary data may be shared with authorized support units.
  • Generating AI-powered responses: Your conversation data, necessary conversation context, and limited transaction data may be processed in order to understand your messages and generate appropriate responses. Such processing is based on the legal ground that it is directly related to the establishment or performance of a contract. Services provided by Cloudflare and OpenAI may be used for this purpose.
  • Ensuring the secure and proper operation of the service: Technical, security, and session data may be processed for the purposes of detecting errors and misuse, ensuring system security, and maintaining the service. Such processing may be based on the legitimate interests of the data controller and, where applicable, compliance with the data controller's legal obligations. Necessary data may be shared with technical infrastructure service providers.
  • Improving Su's knowledge base and response quality: Conversation, usage, feedback, and classification data may be processed for the purposes of identifying incorrect or unanswered questions and enabling Su to provide more accurate responses to future questions. Such processing is based on the legitimate interests of the data controller, provided that such processing does not harm the fundamental rights and freedoms of the data subject. Necessary data may be processed by authorized technical/quality teams and technical service providers.
  • Complying with legal obligations and protecting legal rights: Relevant transaction, application, and record data may be processed for the purposes of complying with obligations arising from applicable legislation and protecting legal rights. Such processing is based on the legal grounds of compliance with the data controller's legal obligations and the establishment, exercise, or protection of a right. Where necessary, data may be shared with public institutions and authorities legally authorized to receive such data.

When processing data for the purpose of improving Su's knowledge base and response quality, personal data that is not necessary for the relevant processing purpose will not be used, and the principle of data minimization shall apply.

6. Method of Collection of Personal Data

During your use of the Su iste Artificial Intelligence Assistant, your personal data may be collected electronically, wholly or partly by automated means, through:

  • Information you provide during your conversations with Su iste AI,
  • The Su iste mobile application and web site,
  • Applications and systems used to fulfil requests from logged-in users,
  • Location information provided by you or obtained in accordance with your device permissions,
  • Usage and classification records generated by the system,
  • Technical and security records generated during the operation of the service,
  • Information provided by you during support processes.

Personal data is processed only to the extent necessary for the relevant processing purpose.

7. Parties to Whom Personal Data May Be Transferred

Your personal data may be shared, limited to the data necessary for the relevant processing purpose, with:

  • authorized employees and support/quality units of the Company,
  • relevant dealers or service units where necessary to fulfil your request,
  • Cloudflare for the provision of technical infrastructure services,
  • OpenAI for processing user messages through artificial intelligence and generating responses,
  • Public institutions and authorities legally authorized to receive such data for the fulfilment of legal obligations,

in accordance with the conditions specified under the KVKK.

8. Transfer of Personal Data Abroad

As services provided by Cloudflare and OpenAI are used in the operation of the Su Artificial Intelligence Assistant, certain personal data processed within the scope of the service may be transferred abroad.

Depending on the service provided and the nature of your request, such transfers may include message content, relevant conversation context, necessary user and transaction information, and limited technical data.

Transfers of personal data abroad are carried out in accordance with Article 9 of the KVKK and the relevant applicable legislation.

9. Data Retention Periods

Your personal data is retained for as long as required by the purposes for which it is processed and within the periods prescribed by applicable legislation.

Where the reasons requiring the processing of personal data cease to exist, the necessary actions will be taken in accordance with the applicable legislation.

10. AI-Assisted Processing and Automated Decisions

Su iste AI may perform AI-assisted processing in order to understand user messages, generate appropriate responses, determine the subject of conversations, and improve service quality.

In this context, the system may generate limited classifications relating to the subject or purpose of the conversation, whether the request has been resolved, sentiment, and response quality.

The Su Artificial Intelligence Assistant is not used for the purpose of making final decisions based solely on automated processing that produce legal effects concerning users or similarly significantly affect them.

11. Data Security

Appropriate technical and administrative measures are implemented to ensure the security of your personal data and prevent unauthorized access, use, disclosure, or loss.

Access to personal data is limited to persons who require such access within the scope of their duties and authorizations, and processing is limited to the personal data necessary for the provision of the service.

12. Your Rights Under the KVKK

Pursuant to Article 11 of the KVKK, you have the right to apply to the data controller and:

  • 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,
  • Know the third parties to whom your personal data has been transferred domestically or abroad,
  • Request the correction of incomplete or inaccurate personal data,
  • Request the deletion or destruction of your personal data where the conditions stipulated under the KVKK are met,
  • Request that correction, deletion, or destruction operations be notified to third parties to whom your personal data has been transferred,
  • Object to any result arising against you as a result of the analysis of processed data exclusively through automated systems,
  • Request compensation for damages where you suffer damage as a result of the unlawful processing of your personal data.

13. Exercising Your Rights and Application Procedure

You may submit requests regarding your rights under the KVKK to the Company through the following channels by clearly stating your identity and request:

  • Email: info@suiste.com
  • By post or in person: Bahçeşehir 2. Kısım Mah. Şelale Cad. Akın Sok. No: 1K Başakşehir/Istanbul, Türkiye

Additional information may be requested to verify your identity in order to ensure that your application is processed securely.

Applications submitted under the KVKK will be concluded as soon as possible and no later than 30 days, depending on the nature of the request. If the processing of the application requires an additional cost, a fee may be charged in accordance with the tariff determined by the Turkish Personal Data Protection Board.

If your application is rejected, you consider the response insufficient, or no response is provided within the prescribed period, you may lodge a complaint with the Turkish Personal Data Protection Board subject to the conditions and time limits specified under the KVKK.

14. Changes to the Privacy Notice

This Privacy Notice may be updated if there are changes to the operation of the Su iste Artificial Intelligence Assistant, the personal data processed, processing purposes, service providers, retention practices, or data transfer processes.

The current version of this Privacy Notice will be made available to users through the Su iste website and/or mobile application.

ANNEX 1 – Short Notice for the Chat Screen

Su iste AI is an artificial intelligence assistant. The messages you enter are processed using artificial intelligence technologies in order to answer your questions and provide support. In this context, services provided by Cloudflare and OpenAI may be used, and certain personal data may be transferred abroad. Please do not share sensitive information such as passwords, card information, Turkish Republic identification numbers, or health information. For further information, please review the Privacy Notice.

ANNEX 2 – Notice Before Requesting Device Location Permission

Would you like to share your location? Your device location will be used to determine your delivery area or the sales point serving you. Sharing your location is optional; you may continue without sharing your device location by entering your province or district information. For further information, please review the Privacy Notice.

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