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This text is a general information and preparation sample. For a concrete customer/business relationship, the necessary party information, permissions, acceptance and, if any, pre-payment documents must be separately completed; displaying this page does not create a contract or mean that permission has been granted.
This text contains explanations on the usage and legal processes of the NEFES Ajansı service. In each section, data, authority and party responsibilities are assessed within their own scope.
Scope and party roles
This annex has been prepared to apply where NEFES processes customer or follower messages, comments and similar third-party data on the relevant business's own social media accounts, in line with the service purpose and instructions determined by that business.
In these activities the business is the data controller, and TRADE YAZILIM SANAYİ VE TİCARET LİMİTED ŞİRKETİ acts as data processor to the extent it acts on instructions. NEFES's own sales, accounting, security or personnel data may have a different role allocation. The full role analysis is carried out according to the customer's actual use.
Subject matter, duration and types of processing
The subject of processing is the collection, organization, storage and retention of data accessed for social media management and customer communication purposes only through the accounts and tools approved by the customer, drafting responses to specific requests, authorized publishing and reporting, and deletion or return operations upon instruction.
The categories of individuals, data fields, connected social accounts, scope of messages and comments, media sent and retention period are specified in the concrete service inventory signed with the customer.
Instructions, purpose limitation and confidentiality
NEFES processes data it handles on the business's behalf only on written or traceable customer instructions and as required by law. It does not mix this data with other businesses' data, and does not turn the customer database into its own independent sales list.
Access is granted only to authorized personnel and to technical providers as required by their duties. Suspected unauthorized use is investigated within a reasonable time and the relevant party is informed.
Sub-processors and overseas services
The account connection engine, SMS, email, hosting, automated analytics and AI content providers may act as sub-processors where needed. The providers and country inventory to be used, along with technical safeguard requirements, are specified in the service annex of the customer agreement.
For transfers of personal data abroad under Law No. 6698, Article 9, this agreement alone does not grant a transfer right unless an appropriate method or safeguard has been established. If a standard contract is required, the official text suited to the roles and recipient type, signature and timely notification are completed separately.
Security, breaches and support
The parties determine technical and administrative measures proportionate to the risk. Account-based authorization, access restriction, identity verification, activity logging, secure backup and necessary deletion controls may serve as examples.
If a personal data breach is suspected, NEFES provides reasonable and prompt information and cooperation so the business can meet its legal notification obligations on time. The definitive incident notification channel and technical timelines should be set out in an agreed operational annex.
Requests, audits and termination
When a data subject request reaches NEFES, it may be directed to the relevant business; NEFES cooperates on correction, access or deletion as instructed by the business. The audit and information-provision procedure, to the extent legally required, is agreed separately by the parties.
Upon end of service, return or deletion options for the business's data, legal retention exceptions, deletion confirmation from sub-processors and the backup cycle are shown in the concrete data plan. This annex may take effect with the customer's explicit acceptance; it is not established automatically by visiting a public page.
For your questions or personal data requests info@nefesajans.com.
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