Privacy Policy
LOKALIA PRIVACY POLICY
Last Updated: 29.01.2026
By accepting this Privacy Policy, you acknowledge that you have been informed about the processing of your personal data and consent to the use of your personal data as specified herein.
This Privacy Policy ("Privacy Policy") outlines the terms and conditions regarding the use of personal data shared by users of the application or personal data generated during the use of the application by Axelle Tech LTD ("Lokalia").
1. INTRODUCTION
Axelle Tech LTD ("Lokalia," "we," "us," or "our"), a company registered in England and Wales (Company Number: 16311724), is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our digital menu services.
We comply with:
- UK GDPR (United Kingdom General Data Protection Regulation)
- KVKK (Turkish Personal Data Protection Law No. 6698)
- Turkish E-Commerce Law No. 6563
2. DATA CONTROLLER INFORMATION
Data Controller: Axelle Tech LTD
Registered Address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
Company Number: 16311724
Email: info@axelletech.com
3. PERSONAL DATA WE COLLECT
Lokalia processes your personal data in accordance with the Personal Data Protection Law (KVKK), categorized as follows. Unless explicitly stated otherwise, the term "personal data" within the scope of this Privacy Policy includes the information listed below.
3.1 Identity and Contact Information
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Name | Account identification, personalization | Contract performance |
| Email address | Account management, communications | Contract performance |
| Phone number | Account recovery, optional notifications | Contract performance |
| Date of birth | Age verification (18+ requirement) | Legal obligation / Consent |
| Profile photo | Account personalization, identification | Consent |
3.2 User Information, Transaction Information, and Behavioral Data (via Cookies)
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Unique Guest ID | Session management, order tracking | Legitimate interest (essential function) |
| Basket items | Order processing | Contract performance |
| Clicked/viewed items | Service improvement, recommendations | Consent (analytics) |
| Time spent on pages | Service optimization | Consent (analytics) |
| Search terms and filtering preferences | Improve user experience | Consent (analytics) |
| Estimated spending/basket totals | Customer insights for restaurants (with consent) | Consent |
| AI chat messages | Provide AI-powered recommendations | Consent |
3.3 Location Information
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Approximate location (from IP address) | Service optimization, fraud prevention | Legitimate interest |
Note: We do not collect precise GPS location data.
3.4 Transaction Security Information
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Login credentials | Account authentication | Contract performance |
| Password (encrypted) | Account security | Contract performance |
3.5 Marketing Information
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Restaurant subscription preferences | Enable restaurant communications | Explicit consent |
| Newsletter opt-in status | Promotional communications | Explicit consent |
| Preferences and habits | Targeting, profiling, personalization | Explicit consent |
3.6 Request/Complaint Management Information
| Data Type | Purpose | Legal Basis |
|---|---|---|
| Support requests and complaints | Customer service | Contract performance / Legitimate interest |
| In-app feedback and ratings | Service improvement | Legitimate interest |
3.7 Risk Management Information
| Data Type | Purpose | Legal Basis |
|---|---|---|
| IP address | Security, fraud detection, error logging | Legitimate interest |
Data Anonymization: Data anonymized under Articles 3 and 7 of the KVKK will not be considered personal data in accordance with the law's provisions, and processing activities related to these data will be conducted regardless of the provisions of this Privacy Policy.
4. HOW WE USE YOUR DATA
The personal data you share with Lokalia may be processed to:
- Fully utilize the services provided through the application
- Register your account and update your account information
- Process your orders and transactions
- Improve the services offered by Lokalia
- Personalize your experience
- Send service-related communications
- Send marketing communications (with your consent)
- Conduct commercial activities, determine and implement commercial and business strategies
- Ensure the legal and commercial security of Lokalia and its business partners
- Comply with legal obligations
- Protect against fraud and abuse
Such personal information may also be used to:
- Contact you or improve your experience on the application (e.g., managing communication processes, conducting satisfaction surveys)
- Perform internal reporting and business development activities, including statistical evaluations, database creation, and market research without disclosing your identity
- Engage in direct marketing, digital marketing, remarketing, targeting, profiling, and analysis purposes (with your consent)
- Notify you about the promotion, maintenance, and support activities of various services based on this information
5. PROCESSING WITHOUT CONSENT (KVKK ARTICLE 5 AND 8 EXCEPTIONS)
Pursuant to Articles 5 and 8 of the KVKK and/or in the presence of exceptions in relevant legislation, Lokalia may process personal data without obtaining separate consent from you as the Data Subject and may share it with third parties under the following circumstances:
- Legal Provisions: Where explicitly provided by laws
- Vital Interests: When necessary to protect the life or physical integrity of the Data Subject or another person due to actual impossibility of obtaining consent or when the consent has no legal validity
- Contractual Necessity: When necessary for the processing of personal data in connection with the establishment or execution of a contract between the Data Subject and Lokalia
- Legal Obligations: When necessary for Lokalia to fulfill its legal obligations
- Public Disclosure: When the Data Subject has made the data public
- Legitimate Interests: When processing data is necessary to establish, exercise, or protect a right, or for Lokalia's legitimate interests without harming the Data Subject's fundamental rights and freedoms
6. AI CHAT DATA PROCESSING
Important Notice: When you use our AI Chat feature, your messages are processed using artificial intelligence technology provided by a third-party service.
- What is processed: Your chat messages and menu context
- Purpose: Generate relevant menu recommendations and answers
- Storage: Chat logs retained for 90 days, then deleted or anonymized
- Your rights: You can request deletion of chat history at any time
Cross-border transfer safeguards (Standard Contractual Clauses) are in place with our AI service provider.
7. DATA SHARING AND RECIPIENTS
We share your data with the following categories of recipients:
| Recipient Category | Data Shared | Purpose |
|---|---|---|
| Restaurants (with your consent) | Name, email, phone, profile photo, preferences, order history, estimated spending | Restaurant services, marketing, customer insights |
| AI service provider | Chat messages | Menu recommendations |
| Authentication provider | Login credentials | User authentication |
| Email service provider | Email, name | Email delivery |
| Hosting service provider | All data (encrypted) | Infrastructure |
| POS providers | No personal data | Menu/order sync |
| Legal advisors (if necessary) | As required | Legal proceedings |
| Public authorities (if legally required) | As required by law | Legal compliance |
Additionally, we may share your data with our shareholders, subsidiaries, and legally authorized institutions as required by law.
Worldwide Server Storage: As a Data Subject, you agree that these third parties may store your personal data on servers worldwide to the extent limited to the purposes mentioned above and consent to this in advance.
8. CROSS-BORDER DATA TRANSFERS
Your personal data is transferred from Turkey to:
- United Kingdom (Lokalia headquarters)
- United States & European Union (third-party service providers)
Safeguards in place:
- Turkish Standard Contractual Clauses (notified to KVKK Authority)
- UK International Data Transfer Agreement (IDTA)
- Data Privacy Framework certification (where applicable)
9. DATA RETENTION
| Data Category | Retention Period |
|---|---|
| Cookie/tracking data | 13 months |
| AI chat logs | 90 days |
| User account data | Duration of account + 6 years |
| Profile photos | Account duration (deleted upon account deletion or request) |
| Inactive accounts | 2 years of inactivity, then deleted |
| Marketing consent records | Duration of processing + 6 years |
| Opt-out/suppression records | Indefinitely |
| Transaction data | 10 years (Turkish Commercial Code) |
| IP address logs | 6 months |
Your personal data is retained for the duration necessary to fulfill the purposes specified in this Privacy Policy and for the statutory limitation periods specified in the relevant legislation. Additionally, your personal data may be retained limitedly in case of any dispute between you and Lokalia to perform necessary defenses in the scope of the dispute.
10. YOUR RIGHTS
Under KVKK (Article 11), you have the right to:
a) Learn whether your personal data is being processed
b) Request information about processing
c) Learn the purpose of processing and whether data is used accordingly
d) Know third parties to whom data is transferred domestically or abroad
e) Request correction of incomplete/inaccurate data
f) Request deletion/destruction of data under Article 7 conditions
g) Request notification of corrections to third parties
h) Object to results arising exclusively from automated decision-making
i) Claim compensation for damages arising from unlawful processing
Under UK GDPR, you additionally have:
- Right to data portability
- Right to restrict processing
- Right to object to processing based on legitimate interests
How to exercise your rights:
Email: info@axelletech.com
Response time: Within 30 days
11. YOUR OBLIGATIONS
As a Data Subject, you commit that the information subject to this Privacy Policy is complete, accurate, and up to date, and that you will promptly update it if any changes occur. Lokalia will not be liable if you do not provide updated information.
As a Data Subject, you acknowledge that if you request that any of your personal data not be used by Lokalia, you may not fully benefit from the operation of the application and agree that any responsibilities arising in this context will be yours.
12. COOKIES
Lokalia may use cookies and, within this scope, process data and share it with third parties only to the extent necessary for providing these services. These technical communication files are small text files sent to the Data Subject's browser by the application to be stored in the main memory. They store status and preference settings about an application, thereby facilitating its use. These files are designed to obtain statistical information about application usage and assist in generating dynamic content and personalized recommendations. They are not designed to obtain any personal data beyond what is stored in the main memory.
For detailed information about our use of cookies, please see our Cookie Policy.
13. CHILDREN'S PRIVACY
Our Services are not intended for individuals under 18 years of age. We do not knowingly collect data from minors. If we learn we have collected data from a minor, we will delete it immediately.
14. SECURITY MEASURES
Lokalia implements appropriate technical and administrative measures, considering cost and practicality, to ensure at least the minimum level of security, including:
- Preventing personal data from being processed unlawfully
- Preventing unlawful access to personal data
- Safeguarding the preservation of personal data
- Encryption in transit (TLS) and at rest
- Access controls and authentication
- Firewalls and intrusion detection
- Regular security assessments
- Employee training on data protection
- Incident response procedures
Lokalia conducts necessary audits to maintain these standards.
Furthermore, Lokalia does not disclose the personal data obtained from you to anyone unlawfully or use it for purposes other than processing, in accordance with this Privacy Policy and the Personal Data Protection Law.
If links to other applications or websites are provided through the application, Lokalia does not bear any responsibility for the privacy policies and contents of these applications and recommends that you review them.
15. CHANGES TO THIS POLICY
This Privacy Policy may be updated from time to time to comply with changing conditions and legislation. Material changes will be communicated via email and/or prominent notice on our Services.
16. CONTACT AND COMPLAINTS
For privacy inquiries:
Email: info@axelletech.com
To lodge a complaint:
Turkey: KVKK Authority (kvkk.gov.tr)
UK: Information Commissioner's Office (ico.org.uk)