Last Updated: [18.11.2025]

Your privacy is important to AS KARE SAĞLIK ÜRÜNLERİ SANAYİ VE DIŞ TİCARET A.Ş. (“AS KARE”). We would like to state that this Privacy Notice may be amended or supplemented from time to time by AS KARE in accordance with changing legislative provisions.

This document is a notice prepared to fulfill the obligation of disclosure under Article 10 of the Personal Data Protection Law No. 6698 (“KVKK”) and the relevant legislation.

DATA CONTROLLER AND PURPOSE OF PROCESSING PERSONAL DATA

AS KARE acts as the data controller for the personal data collected within the scope of this notice in accordance with KVKK and other relevant legislation. The purpose of this notice is to ensure that the data shared with us is processed in compliance with applicable legislation and to inform data subjects about the personal data processing policies carried out by the entities mentioned above pursuant to Article 10 of KVKK titled “Data Controller’s Obligation to Inform”.

Your personal data is processed for the purposes listed below:

Ensuring activities are carried out in compliance with legislation;

Execution of Corporate Governance Policies;

Management of finance and accounting processes;

Follow-up and execution of legal affairs;

Fulfillment of legal obligations;

Conducting communication activities;

Execution of business continuity activities;

Execution of business and audit processes;

Carrying out purchasing, sales, and after-sales processes;

Managing customer relationship processes;

Conducting customer satisfaction activities;

Execution of marketing processes;

Execution of advertising, campaign, and promotional processes;

Management of risk processes;

Execution of contract processes;

Execution of loyalty processes relating to products and services;

Management of requests and complaints;

Execution of product/service marketing processes;

Management of member relations processes;

Providing necessary information and documents to local and central authorities and courts upon request;

Conducting strategic planning activities.

Your personal data is processed under the personal data processing conditions specified in Article 5 of KVKK.

PERSONAL DATA WE PROCESS

AS KARE collects the personal data that you voluntarily share with our Company to conduct transactions on both www.torqnutrition.com.tr and www.aloprotein.com. The categories of personal data we collect and process are listed below:

Identity Information: Name, surname, Turkish ID Number (TCKN)

Contact Information: Email address, postal address, phone number

METHOD AND LEGAL BASIS FOR COLLECTING PERSONAL DATA

Your personal data is collected and processed in line with the purposes stated above and within the scope of the conditions specified in Articles 5 and 6 of KVKK.

Your personal data is collected electronically through the electronic membership agreement and processed in line with the purposes stated above.

Personal data collected on the legal bases of explicit provisions in laws, necessity for establishing or performing a contract, and necessity for complying with legal obligations of the relevant institutions may be processed and transferred for the purposes stated in this notice within the scope of the personal data processing conditions and purposes under Articles 5 and 6 of KVKK.

AS KARE processes personal data in accordance with the data processing principles and obligations specified in the Personal Data Protection Law No. 6698, the Constitution of the Republic of Türkiye, international agreements to which Türkiye is a party, secondary legislation, and the guidelines and decisions published by the Personal Data Protection Authority.

PROCESSING AND TRANSFER OF PERSONAL DATA

AS KARE may transfer the personal and sensitive personal data of data subjects to third parties, institutions, group companies, third natural persons, or entities located domestically or abroad in accordance with lawful data processing purposes and by taking necessary security measures, when required. Such transfers are carried out within the scope of the personal data processing conditions and purposes set forth in Articles 8 and 9 of KVKK.

Personal data may be transferred domestically to third real or legal persons with the explicit consent of the data subject. In cases where explicit consent is not available, data may be transferred only under the following conditions:

Explicitly stipulated by law;

Required to protect the life or physical integrity of a person who is incapable of giving consent due to actual impossibility or whose consent is not legally valid;

Necessary for establishing or performing a contract;

Necessary for the data controller to fulfill its legal obligations;

Personal data made public by the data subject;

Necessary for the establishment, exercise, or protection of a right;

Necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

PROCESSING AND TRANSFER OF SPECIAL CATEGORIES OF PERSONAL DATA

Special categories of personal data may only be processed or transferred by AS KARE with the explicit consent of the data subject.

PURPOSE AND METHOD OF TRANSFERRING PERSONAL DATA

Personal data transferred through the electronic membership agreement may be shared with relevant institutions and organizations solely for the purpose of fulfilling AS KARE’s legal obligations in cases where such sharing is required by applicable legislation or obligations.

In addition, based on the contact information you provide upon creating your membership, your personal data may be shared within the scope of the data controller’s legitimate interests—without harming your fundamental rights and freedoms—for the following purposes:

Processing your orders placed on www.torqnutrition.com.tr or www.aloprotein.com;

Delivery of products and/or services;

Processing your payments;

Contacting you for promotional and advertising purposes regarding our products or services;

Identifying and filtering products that may be of interest to you;

Conducting advertising, promotion, marketing, and communication activities;

Improving service quality and enhancing site experience.

YOUR LEGAL RIGHTS AS A DATA SUBJECT

Regarding your personal data processed by data controller AS KARE, you have the following rights:

To learn whether your personal data is being processed (KVKK Art. 11/a, b)

To request information regarding the processing (Art. 11/b)

To learn the purpose of processing and whether it is used in line with this purpose (Art. 11/c)

To know third parties to whom your data is transferred (Art. 11/ç)

To request correction of incomplete or incorrect data (Art. 11/d)

To request deletion of your personal data when the reasons for processing no longer exist (Art. 7, 11/e)

To request notification of correction or deletion to third parties to whom your data has been transferred (Art. 11/f)

To object to results obtained through analysis of processed data (Art. 11/g)

To request restriction of processing (Art. 7)

To request compensation for damages in case of unlawful processing (Art. 11/ğ)

APPLICATION METHODS WITHIN THE SCOPE OF YOUR RIGHTS

In accordance with the provisions of KVKK and the Communiqué on Procedures and Principles of Application to the Data Controller, you may submit your requests regarding your rights listed above by completing the Data Controller Application Form available at www.torqnutrition.com, together with documents verifying your identity.