Privacy Policy

1. INTRODUCTION

This Privacy Policy ("Policy") explains how RTW Bilişim ve Danışmanlık Anonim Şirketi ("RTW", "we", "us", or "our"), operating the AI Agent TR service at aiagenttr.com ("Service"), collects, uses, stores, and protects your personal data in accordance with the Turkish Personal Data Protection Law No. 6698 ("KVKK"), and where applicable, the UK General Data Protection Regulation ("UK GDPR") and EU General Data Protection Regulation ("EU GDPR").

Data Controller Information

2. DATA CATEGORIES WE PROCESS

2.1 General Personal Data

Account Information:

• Full name, Email address, Phone number
• Business name, title, and registration details

Service Usage Data:

• Call logs, duration, timestamps, and phone numbers
• Call transcripts and API usage statistics
• IP addresses and device information

Payment Information:

• Payment card details (processed via Stripe)
• Transaction history and invoice details

2.2 Special Category Personal Data

Our AI agents are programmed not to solicit special category personal data (health, religion, political views, etc.). However, callers may voluntarily disclose such information during conversations. This data may be captured in voice recordings and transcripts and will be stored for the same retention period as voice recordings.

3. LEGAL BASIS FOR PROCESSING

3.1 Under KVKK

• Performance of contract (Article 5/2-c)
• Legitimate interests (Article 5/2-f)
• Legal obligation (Article 5/2-ç)
• Explicit consent where required (Article 5/1)

3.2 Under UK GDPR / EU GDPR (When Applicable)

• Contract performance (Article 6(1)(b))
• Legal obligations (Article 6(1)(c))
• Legitimate interests (Article 6(1)(f))
• Consent (Article 6(1)(a))

4. DATA PROCESSING PURPOSES

• Operating AI call center services
• Voice-to-text conversion and natural language processing
• Account management and billing
• Customer support and service improvement
• Legal compliance and fraud prevention
• Anonymous AI model training (with opt-out option)

5. DATA STORAGE AND RETENTION

5.1 Storage Locations

• Primary: AWS Frankfurt (EU)
• Voice Processing: Third-party AI voice processing services (with encryption)
• PBX Services: Telecommunications service providers
• Payment: Stripe (UK)
• Future: Migration to Huawei Cloud Turkey planned

5.2 Retention Periods

6. DATA SHARING AND TRANSFERS

6.1 Service Providers

• Third-party AI voice processing services - encrypted transfer
• AWS - Infrastructure (Germany)
• Stripe - Payment processing (UK)
• Telecommunications/PBX service providers

6.2 International Transfers

For transfers outside Turkey, we implement appropriate safeguards including encryption and secure protocols. We ensure adequate protection levels according to KVKK Article 9.

7. DATA SUBJECT RIGHTS

7.1 Your Rights Under KVKK

• Know whether your personal data is processed
• Request information about processing
• Request correction of incorrect data
• Request deletion or destruction
• Object to adverse automated processing
• Claim compensation for damages

7.2 Exercising Your Rights

Submit requests via:

• Email: info@aiagenttr.com
• Data Subject Application Form (available on our website)

We will respond within 30 days per KVKK requirements.

8. SECURITY MEASURES

• End-to-end encryption for voice calls
• TLS/SSL for data transmission
• Multi-factor authentication
• Regular security audits
• Access control and authorization

9. AI-SPECIFIC CONSIDERATIONS

9.1 Voice Processing

We convert voice to text for processing. We do not create voiceprints or use voice biometrics for identification. Authentication is handled by our customers' systems based on the information provided during calls.

9.2 Model Training

We may use anonymized call data for model improvement. Personal identifiers are removed before training. You can opt-out of contribution to model training by contacting us.

10. CHILDREN'S PRIVACY

Our Service is not intended for individuals under 18 years of age. We do not knowingly collect personal data from children.

11. UPDATES TO THIS POLICY

We may update this Policy periodically. Material changes will be notified via email or Service announcement.

12. CONTACT INFORMATION

KVKK Complaints:

Personal Data Protection Authority

Website: www.kvkk.gov.tr