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Draft — Not Legal Advice. This document must be reviewed by a lawyer before publication. Fields in [square brackets] have not yet been filled in.

Privacy Policy

Last updated: [DATE PLACEHOLDER]

1. Introduction

This Privacy Policy is prepared by [COMPANY NAME] ("Yaverin", "we", "us") to inform you about how personal data is processed through the yaverin.com website and Yaverin services.

Yaverin is a platform that enables small and medium-sized businesses ("Merchants") to provide AI-assisted responses to their customers on WhatsApp Business and Instagram Direct. This policy covers site visitors, Merchant clients, and the end-customers of Merchants.

The authoritative version of this policy is in Turkish (/gizlilik), which governs in the event of any conflict.

2. Yaverin's Role: Data Processor

When processing personal data of a Merchant's end-customers, Yaverin acts as a data processor. The Merchant is the data controller for that data under applicable law, including Turkey's Personal Data Protection Law (KVKK).

Yaverin processes such data solely on the Merchant's instructions and for the purpose of providing the service. It does not share this data with third parties or use it for its own commercial purposes.

For data collected directly from site visitors and Merchant clients, Yaverin acts as the data controller.

3. Personal Data We Process

3.1 End-Customer Data (as Data Processor)

The following data is processed to deliver the service on behalf of Merchants:

  • Name and contact details (as shared via WhatsApp/Instagram)
  • Message content and conversation history
  • Order information (pulled from the Merchant's connected e-commerce system)
  • Communication channel and timestamps

3.2 Merchant Data (as Data Controller)

  • Business name, authorized contact details
  • Uploaded knowledge base content (product catalog, FAQs, policies)
  • Platform usage and analytics data
  • Billing and payment information

3.3 Site Visitor Data (as Data Controller)

  • Name, email, and message submitted via the contact form
  • Technical log data (IP address, browser type, visit timestamp)

4. Purposes and Legal Bases

  • Performance of a contract: Processing necessary to provide the service you have subscribed to.
  • Legitimate interests: Service security, quality improvement, and fraud prevention, where these do not override your rights.
  • Legal obligation: Compliance with applicable data retention requirements.
  • Consent: For marketing communications, where required by law.

5. Data Retention

  • Conversation history: period set by the Merchant or up to [X months/years]
  • Merchant account data: [X years] after account closure
  • Contact form submissions: [X years] after the request is resolved
  • Log records: up to [X months]

Data is securely deleted when retention periods expire.

6. Data Sharing

Personal data may be shared with third parties in the following circumstances:

  • Sub-processors: Cloud infrastructure, email delivery, and analytics providers used to operate the service ([PROVIDER LIST PLACEHOLDER]). These providers are contractually bound to comply with applicable data protection standards.
  • The Merchant: End-customer data is shared with the relevant Merchant as data controller.
  • Legal requirement: Where required by court order or applicable law.

Your data is never sold or shared for advertising purposes.

7. Data Security

Yaverin applies technical and organizational measures to protect personal data, including:

  • TLS encryption in transit and at rest
  • Access controls and role-based authorization
  • Regular security reviews
  • Staff confidentiality obligations

8. Your Rights

You have the right to request access to, correction of, or deletion of your personal data. Under KVKK Article 11, you also have the right to object to automated processing and to request that we restrict processing in certain circumstances.

To exercise these rights, contact us at hello@yaverin.com.

9. Cookies

The Yaverin marketing site uses only essential technical cookies. No advertising or third-party tracking cookies are used. Where Cloudflare Web Analytics is active, it operates without cookies and collects only anonymous, aggregated data.

10. Policy Updates

This policy may be updated from time to time. Material changes will be announced on the site. The current version is always available at yaverin.com/en/privacy.

11. Contact

For privacy-related questions: hello@yaverin.com

Legal Information

Company Name
[ŞİRKET UNVANI]
Registered Address
[KAYITLI ADRES]
Tax Office
[VERGİ DAİRESİ]
Tax ID
[VERGİ NO]
Contact
hello@yaverin.com
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[ŞİRKET UNVANI] · [KAYITLI ADRES] · Tax Office: [VERGİ DAİRESİ] · Tax ID: [VERGİ NO]

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