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COMMERCIAL ELECTRONIC MESSAGE DISCLOSURE

Last Updated: 13.03.2026

1. PURPOSE

This disclosure informs you about your rights regarding commercial electronic messages sent through the Lokalia platform, in accordance with Turkish Electronic Commerce Law No. 6563 ("ETK"), the Regulation on Commercial Communication and Commercial Electronic Messages, UK GDPR, EU GDPR, and the Privacy and Electronic Communications Regulations (PECR).

2. PARTIES AND ROLES

2.1. Service Provider / Intermediary Service Provider

Axelle Tech LTD ("Lokalia") Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom Company Number: 16311724 Email: info@axelletech.com

Lokalia acts as an intermediary service provider for the sending of commercial electronic messages. Lokalia provides technical email delivery services on behalf of restaurants using third-party email infrastructure. The content, recipient list, and timing of the emails are determined by the restaurant.

2.2. Sender (Restaurant)

Emails are sent from the restaurant's own domain. Each email clearly identifies the sending restaurant. The restaurant is the service provider under ETK and the data controller under KVKK/GDPR.

3. CONSENT MECHANISM

Your explicit consent is required to receive commercial electronic messages. Consent is obtained through:

(a) Through the Lokalia Platform: When using the digital menu, if you give explicit consent (via opt-in mechanism) for the restaurant to send you commercial electronic messages. When you use the menu anonymously (without creating an account), no commercial message consent is requested and your email address is not collected.

(b) By the Restaurant: Through consents lawfully obtained by the restaurant from its customers outside the platform and uploaded to the system.

Important: Your consent must always be voluntary, informed, and explicit. Pre-ticked boxes do not constitute valid consent.

4. CONTENT OF MESSAGES SENT

Commercial electronic messages sent through the Lokalia platform may include:

  • Restaurant campaigns and promotions
  • Special occasion greetings (birthday, etc.)
  • New menu items and updates
  • Visit reminders
  • Monthly newsletters

Each commercial electronic message includes:

  • The sending restaurant's name and contact information
  • A clear indication that the message is commercial in nature
  • An unsubscribe (opt-out) link

5. YOUR RIGHTS

5.1. Right to Opt-Out

  • You can refuse to receive messages at any time using the "Unsubscribe" link at the bottom of each commercial electronic message.
  • Your opt-out request will be processed within 3 business days at the latest.
  • Opting out is free of charge.
  • Your opt-out applies only to the relevant restaurant's messages. You must exercise your opt-out right separately for messages from different restaurants.

5.2. IYS (Message Management System -- Turkey)

Under the ETK, recipients in Turkey who do not wish to receive commercial electronic messages can manage their preferences through the Message Management System (İYS). IYS registration and consent management are the responsibility of the sending restaurant.

For information about IYS: iys.org.tr

5.3. Additional Rights under UK/EU GDPR

  • Right to object to processing (GDPR Article 21)
  • Right to withdraw consent (GDPR Article 7)
  • Right to object to profiling for direct marketing purposes

5.1 FEATURE AVAILABILITY

Email/SMS marketing services are not available at all restaurants. This feature depends on the restaurant's selected service package (Growth or Max). Restaurants on the Basic package cannot send email/SMS marketing.

6. COMPLAINTS

For complaints regarding commercial electronic messages:

  • Lokalia (Intermediary Service Provider): info@axelletech.com
  • Relevant Restaurant: Contact information available in the sender details of the email
  • Turkey: Ministry of Commerce -- ticaret.gov.tr | KVKK Authority -- kvkk.gov.tr
  • United Kingdom: Information Commissioner's Office -- ico.org.uk
  • EU: Your local Data Protection Authority

7. DATA PROCESSING

For detailed information about personal data processed in connection with commercial electronic messages (name, email address, preference and consent records), please see our Privacy Policy.