This Notice has been prepared by VRT Yazılım Bilişim ve Danışmanlık Hizm. Tic. Ltd. Şti. ("FlexInbox" / the "Company") in its capacity as Data Controller, pursuant to Article 10 of the KVKK (Turkish Personal Data Protection Law No. 6698) (the "KVKK") and the Communiqué on the Principles and Procedures to Be Followed in Fulfilling the Obligation to Inform.
1. Identity of the Data Controller
| Legal name | VRT Yazılım Bilişim ve Danışmanlık Hizm. Tic. Ltd. Şti. |
|---|---|
| Tax No. | 9251287608 |
| MERSIS No. | 0925128760800001 |
| Address | Nişantaş Mh. Demiryolu Cd. No:5/111 Selçuklu/Konya |
| Phone | +90 850 307 43 15 |
| destek@flexinbox.io | |
| Web | https://flexinbox.io |
2. Personal Data Processed
- Identity: full name
- Contact: email, phone/WhatsApp number
- Customer transaction: message content, delivery time, media files, CRM record matches
- Financial: subscription/order, billing title, tax/identification number, payment transaction metadata (card details are not stored)
- Transaction security: IP address, log records, session/authentication tokens
3. Purposes of Processing Personal Data
- Providing the CRM (Zoho, Bitrix24, HubSpot, GoHighLevel) integration service via WhatsApp/Telegram, synchronizing messages, and responding through the AI agent,
- Managing customer relationships and communication records,
- Account creation, authorization, and user management,
- Ensuring information security and preventing misuse,
- Fulfilling legal obligations and billing.
4. Legal Bases for Processing (Article 5 of the KVKK)
- Being directly related to the establishment or performance of a contract,
- The Data Controller's fulfillment of its legal obligation,
- Legitimate interest, provided that it does not harm the fundamental rights and freedoms of the Data Subject,
- The Data Subject's explicit consent where required.
5. Method of Collecting Personal Data
Personal data is collected by automated and partially automated means in electronic form through the web panel, registration forms, CRM integrations (Zoho, Bitrix24, HubSpot, GoHighLevel), and WhatsApp/Telegram sessions.
6. Transfer of Personal Data (Articles 8–9 of the KVKK)
For the purpose of providing the service and with the necessary security measures in place, your data may be transferred to hosting/infrastructure providers; to integration providers such as WhatsApp (Meta), Telegram, Zoho, Bitrix24, HubSpot, and GoHighLevel (LeadConnector); to the model provider used for AI responses (OpenAI); to the payment infrastructure (iyzico); to the e-invoice provider (Logo İşbaşı); to the error-monitoring service (Sentry); and to legally authorized public institutions and organizations. Since some of these services may process data abroad, transfers are carried out in accordance with the conditions set out in Article 9 of the KVKK (explicit consent or adequate safeguards).
7. Rights of the Data Subject (Article 11 of the KVKK)
As a personal data owner, you have the following rights:
- To learn whether your personal data is being processed and, if so, to request information about it,
- To learn the purpose of processing and whether the data is used in accordance with that purpose,
- To know the third parties to whom the data is transferred domestically or abroad,
- To request correction if the data has been processed incompletely or inaccurately,
- To request its deletion/destruction within the framework of the conditions set out in Article 7 of the KVKK,
- To request that correction/deletion operations be notified to the third parties to whom the data was transferred,
- To object to a result being reached against you as a result of analysis by automated systems,
- To request compensation for damages in the event that you suffer harm due to unlawful processing.
8. Application Method
You may submit your requests concerning your rights in writing to destek@flexinbox.io or to the physical address stated above. Your applications will be concluded within 30 days at the latest. In your application, you must clearly state your request together with information verifying your identity.