Privacy & Data Protection
Privacy Policy
How we collect, use, and protect your personal data
How we collect, use, and protect your personal data
As Kynic Agent, we value your privacy and the protection of your personal data. This Privacy Policy (“Privacy Policy”) explains how personal data is collected, used, stored, transferred, and protected in connection with the websites, platform, applications, and related services operated by Kynic Agent.
Kynic Agent is operated by Muhammed Eren Akbaş – Kynic Agent, operating under the laws of the Republic of Türkiye. In this Privacy Policy, we will refer to ourselves as “Kynic Agent,” “we,” or “us.”
This Privacy Policy governs the principles applicable to the processing of personal data of individuals who use Kynic Agent's websites, including kynicagent.com and its relevant subdomains (“Site”), the Kynic Agent platform, applications, and related services (“Services”), as well as Kynic Agent customers who use the Services (“Customer”) and their end users.
If you use the Kynic Agent Services on behalf of a business, the Terms of Service, applicable agreements, and, where applicable, the Data Processing Agreement may also apply to data you transfer to the Services concerning that business's customers, users, or other individuals.
Terms relating to the use of the Site are also governed by the Website Terms of Use. Details regarding the use of cookies and similar technologies are explained in the Cookie Policy.
Kynic Agent may update this Privacy Policy from time to time in accordance with applicable legislation, changes to the Services, or developments in data processing practices. The updated Privacy Policy will become effective when published on the Site or Services or on the stated effective date.
The following terms used in this Privacy Policy shall have the meanings set forth below unless expressly stated otherwise:
Kynic Agent collects different categories of information depending on the nature of the Services provided and your relationship with Kynic Agent.
When you visit the Site, certain technical or usage information may be automatically collected, including:
When you register for or use the Kynic Agent Services, your first name, last name, email address, business information, account information, contact information, and other information necessary to provide the Services may be collected.
Content, messages, instructions, configurations, files, information, and other data transferred to Kynic Agent by the Customer or processed through the Services may be processed. The nature of this data may vary depending on how the Customer uses the Kynic Agent Services.
If a Customer communicates with its customers or end users using the Services, personal data relating to those individuals may pass through Kynic Agent's systems or may be processed by Kynic Agent on behalf of the Customer. Such data may include, for example, names, contact information, message content, information provided by the user, or other categories of data determined by the Customer.
When a Customer uses the Kynic Agent Services together with third-party platforms, messaging systems, communication channels, social platforms, or other integrations, data may be received from or sent to such platforms depending on the authorization provided by the Customer and the technical capabilities of the relevant platform. Kynic Agent aims to process only the data necessary for the operation of the relevant Service or authorized by the Customer.
Access records, transaction records, error logs, security incidents, device information, and similar technical information may be processed to ensure the security, performance, and continuity of the Services.
Where paid Services are used, information necessary for payment and billing processes may be processed. Full payment card information may be processed through the infrastructure of the payment service provider used and may not be directly stored by Kynic Agent.
Cookies, pixels, local storage, and similar technologies may be used on the Site and Services. The types and purposes of these technologies and how preferences may be managed are explained in the Cookie Policy.
Kynic Agent aims to limit the collection and processing of personal data that is not necessary for providing the Services.
(a) Kynic Agent does not intentionally seek to collect personal data that is not necessary for the purposes of the Services.
(b) Kynic Agent aims to process Customer Data only in connection with the provision of the Services, security, technical operation, performance of actions requested by the Customer, or purposes required under applicable legislation.
(c) Kynic Agent has not designed its Services for the intentional collection of personal data belonging to children.
(d) If an individual sends special category or sensitive personal data to Kynic Agent that is not necessary for the purposes of the Services, the processing of such data may be the responsibility of the relevant Customer or data controller.
Kynic Agent aims to take reasonable technical and administrative measures to minimize, protect, and, where applicable, delete unnecessary sensitive data sent to it.
Information collected or processed by Kynic Agent may be used for the following purposes:
(a) Provision of Services: Creating and managing accounts, operating the Services, fulfilling customer requests, and providing Kynic Agent features.
(b) Service Improvement: Evaluating and improving the performance, reliability, and usability of the Services.
(c) Technical Support: Responding to user or Customer requests, identifying errors, and resolving technical issues.
(d) Security and Prevention of Misuse: Detecting and preventing unauthorized access, misuse, fraud, attacks, malicious activities, and other activities that threaten the security of the Services.
(e) Legal Obligations: Fulfilling obligations arising from applicable legislation, responding to lawful requests from competent authorities, and exercising or defending our legal rights.
(f) Communication: Communicating with users and Customers regarding account, Service, security, technical changes, contractual matters, or other necessary notifications.
(g) Anonymized and Aggregated Data: Where data has been anonymized or aggregated in a manner that does not allow the identity of individuals to be identified or reasonably re-identified, such information may be used for the security and performance of the Services, analysis of usage trends, and development of new features.
This provision does not, by itself, permit the use of non-anonymized or non-aggregated Personal Data or Customer Data for general product development purposes.
Kynic Agent may use artificial intelligence and machine learning technologies to provide certain features of the Services.
(a) Use of Artificial Intelligence Services: Kynic Agent may use artificial intelligence technologies to process, classify, analyze, summarize, generate responses to, and otherwise handle messages or other user inputs for the purpose of providing relevant functionality.
(b) Artificial Intelligence Providers: Kynic Agent may use different artificial intelligence technologies and providers depending on the nature and technical requirements of the Services.
These may include OpenAI, Anthropic, Google Gemini, and open-source or self-hosted artificial intelligence models and related infrastructure operated or used by Kynic Agent.
Providers and services used may change over time. Current third-party service providers are identified on the Subprocessors page.
(c) Data Transferred to Artificial Intelligence Systems and Data Masking: When an artificial intelligence feature is used, messages and contextual data necessary for the operation of the relevant feature may be transferred to artificial intelligence services.
To protect data privacy, Kynic Agent aims to scan and mask Personally Identifiable Information (PII - First Name, Last Name, Phone Number, Email, Turkish National ID Number (TCKN), etc.) contained in messages through an automated data masking layer before data is sent to external artificial intelligence systems, and transmits only masked text content to external systems.
(d) Artificial Intelligence Model Training: Kynic Agent does not use Customer Data or personal data belonging to Customers' End Users to train or improve its own general-purpose artificial intelligence models. Kynic Agent does not intend to transfer Customer Data to third-party artificial intelligence providers for the purpose of training or improving general-purpose artificial intelligence models.
Kynic Agent aims to use appropriate configurations for the artificial intelligence services it uses, consistent with the relevant provider's commercial/API services and contractual terms, and to implement contractual and technical arrangements designed to prevent Customer Data from being used for general-purpose model training.
However, limited data processing carried out by a particular artificial intelligence provider for purposes such as data retention, abuse detection, security, debugging, or operation of the service is not the same as model training.
(e) Agreements with Artificial Intelligence Providers: Where appropriate, Kynic Agent works with artificial intelligence providers under agreements or data processing addenda (“DPAs”) governing data processing, privacy, and security obligations.
Depending on the nature of the relevant service, these agreements may govern data processing purposes, confidentiality, security, data retention, and other data protection obligations.
(f) Artificial Intelligence Processing Locations: The fact that Kynic Agent's primary application, database, and related server infrastructure are located in Türkiye does not necessarily mean that artificial intelligence services are also processed in Türkiye.
Depending on the artificial intelligence provider used and the technical architecture of the relevant service, AI requests may be processed through data centers, servers, or service infrastructure located outside Türkiye.
(g) Retention and Logging Practices of Artificial Intelligence Providers: Artificial intelligence providers may retain certain technical records or request and response data for limited periods for purposes such as security, prevention of misuse, technical support, error detection, operation of the service, or fulfillment of contractual obligations.
These periods may vary depending on the provider, service type, account configuration, and applicable contractual terms.
Kynic Agent uses appropriate configurations for commercial/API services where reasonably possible, taking into account the relevant provider's data protection and retention conditions.
(h) Kynic Agent's Own Artificial Intelligence Models: Self-hosted or open-source artificial intelligence models used by Kynic Agent may be operated on infrastructure controlled by Kynic Agent without sending data to a third-party artificial intelligence provider.
Where such systems are used, the relevant data will be subject to the technical and security configuration of the infrastructure used.
(i) Artificial Intelligence Outputs: Responses generated by artificial intelligence systems may contain inaccurate, incomplete, misleading, outdated, or unsuitable results for a particular purpose. AI-generated content should not be relied upon as definitive or professional advice on its own, particularly in relation to legal, financial, medical, security, or other high-stakes decisions.
The processing of a request and generation of a response by an artificial intelligence provider does not, by itself, mean that the relevant data is used to train an artificial intelligence model.
Kynic Agent may share Personal Data and other information with third parties only to the extent necessary for the relevant processing purpose and in accordance with applicable legislation.
(a) Subprocessors and Service Providers: Kynic Agent may use third-party service providers offering hosting, database, storage, security, analytics, communications, payment, artificial intelligence, and similar services to provide the Services.
(b) Artificial Intelligence Providers: Data necessary for the operation of AI features of the Services may be transferred to the relevant artificial intelligence providers.
Such providers may be identified on Kynic Agent's Subprocessors list.
(c) Infrastructure Providers: Service providers used to operate Kynic Agent's application, database, storage, and other technical infrastructure may process certain Personal Data or technical data.
(d) Payment and Billing Providers: Information may be shared with relevant payment or financial service providers to process payments and conduct billing and accounting activities.
(e) Legal and Regulatory Purposes: Kynic Agent may share Personal Data with competent persons, institutions, or organizations where required under applicable legislation, to comply with lawful requests from competent authorities, or to protect its legal rights.
(f) Merger, Acquisition, or Business Transfer: If all or a substantial portion of Kynic Agent is transferred as part of a merger, acquisition, restructuring, business transfer, or asset transfer, relevant information may be transferred to parties involved in the transaction in accordance with applicable legislation.
(g) Security and Prevention of Misuse: Necessary information may be shared with relevant parties to prevent and investigate fraud, attacks, unauthorized access, security breaches, or other unlawful activities.
Kynic Agent does not sell Personal Data or rent Personal Data to third parties for independent advertising purposes.
The fact that Kynic Agent's primary application, database, and related infrastructure are located in Türkiye does not mean that all data processed within the scope of the Services is processed exclusively within the borders of Türkiye.
(a) Primary Infrastructure in Türkiye: Kynic Agent's primary application, database, and related infrastructure components controlled or used by Kynic Agent may be located in Türkiye.
(b) Service Providers Outside Türkiye: Certain third-party service providers or Subprocessors used by Kynic Agent may operate in different countries.
(c) Artificial Intelligence Processing: Requests sent to artificial intelligence services and related data may be processed on systems located outside Türkiye depending on the infrastructure of the artificial intelligence provider used.
Accordingly, the data of a Customer or End User may be transferred outside Türkiye when an AI feature is used.
(d) Data Transfer Mechanisms: Where Personal Data is transferred outside Türkiye, Kynic Agent aims to use appropriate data transfer mechanisms, safeguards, or other legal bases required under applicable data protection legislation.
Where applicable, this may include contractual safeguards, adequacy decisions, or other lawful transfer mechanisms provided for under the relevant legislation.
The role of Kynic Agent with respect to Personal Data may vary depending on the purpose for which the data is processed and on whose behalf it is processed.
(a) Processing Where Kynic Agent Is the Data Controller: Kynic Agent may be the data controller under applicable legislation with respect to Personal Data processed in connection with Site visitors, Kynic Agent accounts, customer relationships, billing, security, marketing, and the operation of Kynic Agent's own business activities.
(b) Processing Where Kynic Agent Is the Data Processor: With respect to data processed by Kynic Agent on behalf of a Customer and in accordance with purposes determined by the Customer, such as Personal Data belonging to the Customer's End Users, Kynic Agent may act as a data processor or in a similar capacity under applicable legislation.
(c) Customer as Data Controller of Customer Data: With respect to End User data transferred to the Kynic Agent Services by a Customer and processed for the Customer's purposes, the Customer may in most cases be the data controller or otherwise the party determining the purposes of processing.
The Customer is responsible for ensuring that Personal Data transferred to the Services has been collected, processed, and transferred to Kynic Agent lawfully.
(d) End User Requests: Customers' End Users should generally submit requests concerning their Personal Data processed for purposes determined by the Customer directly to the Customer.
Where applicable, Kynic Agent may provide technical or administrative assistance to the Customer in fulfilling such requests.
If an End User contacts Kynic Agent directly, Kynic Agent may, depending on the nature of the request and its role in the relevant processing, direct the request to the Customer or coordinate with the Customer.
(e) Data Processing Agreement and DPA: Where a Customer instructs Kynic Agent to process Personal Data as a data processor, a separate Data Processing Agreement may apply between the parties.
The DPA may provide further details regarding data categories, processing purposes, obligations of the parties, security, Subprocessors, data breaches, international transfers, and deletion or return of data.
Kynic Agent aims to implement appropriate technical and administrative measures to protect Personal Data and Customer Data.
However, no method of transmission over the Internet or method of electronic storage can guarantee absolute security.
Kynic Agent aims to retain Personal Data and other information only for as long as required for the relevant processing purposes or for as long as required under applicable legislation.
(a) Retention Periods: Retention periods may vary depending on the nature of the data, the purpose of processing, the agreement with the Customer, legal obligations, security requirements, and potential legal disputes.
(b) Customer Data: Customer Data may be retained for as long as necessary to provide the Services and as required under the agreement with the Customer.
The deletion, return, or retention of data following termination of the agreement may be governed by the applicable Terms of Service, agreement, or DPA.
(c) Account and Transaction Information: Account, billing, transaction, and contractual records may be retained for the period required by legal or accounting obligations.
(d) Technical Logs: Technical logs created for security, error detection, performance, and operation of the Services may be retained for as long as necessary for the relevant purposes.
(e) Retention by Artificial Intelligence Providers: The retention period for data sent to artificial intelligence services may vary depending on the service type, contractual terms, and technical configuration of the provider used.
Kynic Agent takes into account the applicable data protection and retention conditions of the relevant provider when using appropriate commercial/API services.
(f) Account Termination: Closing an account or terminating the Services does not necessarily mean that information Kynic Agent is legally required to retain will be immediately deleted.
Once applicable legal retention obligations have expired, relevant data will, where applicable, be deleted, anonymized, or otherwise removed from processing.
Depending on applicable legislation, you may have various rights regarding your Personal Data.
(a) Rights under the KVKK: Under the Personal Data Protection Law (“KVKK”), where applicable, you may have the right to learn whether your Personal Data is being processed, request information about such processing, learn the purpose of processing and whether the data is used in accordance with that purpose, learn the third parties to whom the data is transferred, request correction where the data is incomplete or inaccurate, request deletion or destruction where the legal conditions are met, and exercise other applicable rights.
(b) Other Data Protection Laws: Where the processing of your Personal Data is subject to the GDPR or other data protection legislation, you may have rights of access, rectification, erasure, restriction of processing, data portability, objection, or other rights under the relevant legislation.
(c) Requests from Customers' End Users: If your Personal Data is processed by Kynic Agent on behalf of a Customer, you may be required to direct your rights request to the Customer in the first instance.
(d) Requests Made to Kynic Agent: Requests made directly to Kynic Agent will be evaluated according to Kynic Agent's role with respect to the relevant data.
Where Kynic Agent acts as a data processor, the Customer may be contacted or coordination may be required to fulfill the request.
(e) Request and Application Process: You may submit requests relating to your Personal Data to Kynic Agent using the contact information below. Applications may be required to comply with the form and procedures prescribed by applicable legislation.
Kynic Agent may request additional information for the purpose of verifying your identity or clarifying the scope of the request.
Kynic Agent Services are generally designed to be used by adult users and businesses.
Kynic Agent does not intentionally seek to collect Personal Data belonging to individuals under the age of eighteen (18).
If it is determined that Personal Data belonging to a child has been improperly transferred to Kynic Agent, reasonable measures may be taken to delete the relevant data or restrict its processing in accordance with applicable legislation.
With respect to Personal Data belonging to children transferred to the Kynic Agent Services by a Customer, the Customer may be responsible for ensuring that such data is collected and processed lawfully.
The Site or Services may contain links to or integrations with third-party websites, applications, platforms, or services.
When third-party services are used, the privacy policies and terms of use of those services may also apply.
Kynic Agent is not responsible for the data processing activities of third parties or applications outside Kynic Agent's control.
With respect to third-party platforms connected to Kynic Agent by a Customer and data transferred from such platforms to Kynic Agent, the terms of the relevant platform and the Customer's authorizations may also apply.
Kynic Agent may use cookies and similar technologies to operate the Site and Services, support security, analyze usage statistics, and improve the user experience.
The purposes for which cookies are used, the types of cookies used, and how cookie preferences may be managed are explained in detail in the Cookie Policy.
Kynic Agent's use of cookies is managed taking into account user preferences and applicable legislation where required.
Kynic Agent may update this Privacy Policy from time to time due to changes in applicable legislation, new features of the Services, changes in technologies or service providers used, or developments in data processing practices.
The updated Privacy Policy will become effective when published on the Site or Services or on the effective date specified in the document.
Where significant changes are made, an appropriate notification method may be used where applicable.
You are advised to review the current Privacy Policy regularly.
This Privacy Policy may be used to contact Kynic Agent regarding the processing of your Personal Data, your data protection rights, our privacy practices, or other matters covered by this Policy.
For requests relating to your Personal Data to be legally valid and properly evaluated, you may be required to comply with the form and procedures prescribed by applicable legislation.
Kynic Agent does not restrict any right to submit an application or complaint to competent supervisory or regulatory authorities responsible for the protection of Personal Data under applicable legislation.