LEGAL
KVKK Data Protection Disclosure
Last updated: August 2026
This is a draft; legal review is recommended before publication.
Prepared under Article 10 of Turkish Law no. 6698 on the Protection of Personal Data (“KVKK”) to inform you about the processing of your personal data. The Turkish text is authoritative.
1. Identity of the data controller
Data controller: Response360 [company name / address / VERBİS registration no]. Contact: [email protected].
2. Personal data processed
- Identity/contact: phone number, email address.
- Customer communication: message content and attachments.
- Transaction security: log records, IP address, timestamps.
- Account information of the customer (tenant) and authorized users.
3. Purposes of processing
- Running omnichannel customer communication and support processes.
- AI message triage and selection of a suitable FAQ answer.
- Routing sensitive or uncertain messages to a human queue.
- Consent-based commercial electronic messaging (broadcast).
- Billing, account management, information security and audit.
4. Legal basis for processing
Your personal data is processed under KVKK art. 5/2 on the bases of contract performance, legal obligation and the controller’s legitimate interest; and, for commercial electronic messages, under art. 5/1 on the basis of explicit consent.
5. Transfers and sub-processors
Your data is processed via infrastructure and sub-processors located in the EU (Frankfurt) region: AWS SES (eu-central-1), MongoDB Atlas (Frankfurt), a WhatsApp Business Platform provider, and an OpenAI-compatible AI provider. Where any cross-border transfer occurs, the conditions of KVKK art. 9 are observed.
6. Retention period
Message and queue data is retained for a TTL defined by RETENTION_DAYS and automatically deleted afterward. Opt-out records are retained to prevent renewed contact.
7. Your rights under KVKK art. 11
- To learn whether your personal data is processed and request information about it.
- To learn the purpose of processing and whether it is used accordingly.
- To request correction if processed incompletely/incorrectly.
- To request erasure or destruction.
- To object to processing and seek remedy for damages.
You may submit requests to [email protected]. [Written application address / KEP address to be added.]