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Müşavir

Data Processing

You own your records; we process them on your behalf

For the customer, employee and supplier data you enter into the platform, your company is the data controller; Müşavir is the party that processes it on your instructions only. This page explains which data each module processes, for what purpose and for how long.

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We have two different roles

Where we act as processorWhere we act as controller
The tenant's customer, lead and supplier recordsThe subscribing company's account and billing details
Personnel, leave, attendance and payroll data of the tenant's employeesSign-in and session records of panel users
Inbox conversations, files, proposal and reconciliation counterpartiesMarketing site visitors and contact form requests

Data categories per module

The list shows the categories each module is designed to handle. You decide which fields you fill in.

ModuleData categoriesPurpose
CRMIdentity, contact details, source, notes, appointments, custom fields you defineManaging customer and lead relationships
Conversation TrackingConversation notes (free text), conversation channel (phone, WhatsApp, in person, email), the employee who held the conversation, planned call and reminder dates, the lead's source and source detail (e.g. ad campaign name)Tracking conversations with leads and customers, planning calls and reminders, sending the team a daily list, producing a conversation report
Proposals and salesContact details, line items, amounts, signature statusQuoting, tracking contracts and sales
BookkeepingCompany name, tax ID, invoices, payments, bank transactionsRecord keeping, collections and reporting
E-reconciliationCounterparty name, email, balance, uploaded statementConfirming current-account balances with the other side
HRIdentity, contact, personnel file, leave, attendance, pay, bank account; may include special categories such as sick notesPersonnel management, leave and payroll preparation
InboxConversation metadata, message preview, ad source signals; full message bodies are not stored on the platform and stay in the messaging account you connectTracking messages in one list, automatically opening a lead record from an incoming message or matching it to an existing customer
FilesContents of documents you uploadStoring and sharing documents inside the company
AIIn AI chat, the message you write, the conversation history and the AI agent's instructions (chat does not access your panel records); content of documents read (processed on the platform's own servers); if the automated task is on, conversation text from the connected messaging account and the lead recordAnswers and drafts in chat, document reading; in the automated task, updating the lead record based on conversations

Why roles matter

KVKK and GDPR hold every party that handles data responsible according to its role. When you enter a customer record into the platform, you decide why and how it is processed, so you are the data controller. Müşavir stores, displays and processes that record on your behalf, so it is the data processor. Informing data subjects, obtaining explicit consent where needed and choosing the legal basis are the controller’s tasks.

For our own subscribers’ account details, panel session records and requests that reach our marketing site, Müşavir is the controller. That data is described in our privacy policy.

Processing on your instructions

  • We process tenant data only to provide the service, answer your support requests, keep the platform secure and meet legal obligations.
  • We do not sell tenant data, use it for ad targeting or give it to AI model training.
  • We aim to bind the subprocessors we work with directly to obligations at the same level; for AI requests, the request reaches the model provider (such as Anthropic) through OpenRouter; the list is on the subprocessors page.

Conversation report and morning email

You can export the conversation report to Excel. The report contains conversation notes, call dates, and the days and direction of messaging; message content is not exported. Every export is written to the audit trail. Each morning your team members receive an email listing their appointments and tasks for the day; the list includes person names and is sent through our existing email subprocessor, Mailgun.

Retention approach

  • During the subscription: Records are kept until you delete them. Deletion is done from the panel, subject to permissions. Statutory retention periods for accounting records are your responsibility; the platform keeps those records unless you delete them.
  • When the subscription ends: You get time to export, after which data is deleted from the live system. Copies in backups expire on their own when the backup retention cycle completes.
  • Conversation records: When you delete a person, their conversation notes are deleted too; their open calls and reminders are archived.
  • Audit trail: Actions such as deletions, exports and changes made by AI are written to the audit trail with who and when.
  • Security and operational logs: Kept for a limited period for troubleshooting and security.

Data processing agreement

We sign a data processing agreement on request. It covers the subject and duration of processing, data categories, technical and organizational measures, subprocessor approval, cross-border transfer safeguards, breach notification, and return and deletion at the end of the contract. When you switch on AI features, your responsibility to inform the people concerned and obtain explicit consent where needed, and the cross-border transfer in those features, are also covered by the agreement. Send your request through the contact page.

Frequently asked questions

Do you sign a data processing agreement?

Yes. We sign a data processing agreement on request. It covers the subject and duration of processing, security measures, subprocessors, cross-border transfer, and return and deletion of data at the end of the contract. Send your request through the contact page.

What if I upload my employees' sick notes?

Health data is a special category of personal data under KVKK. As the controller you provide the legal basis and the privacy notice. We recommend restricting such documents so that only people with HR permissions can see them.

What data can I put in custom fields?

You can define your own fields (text, number, choice, date, yes/no) on the lead and customer card, and you decide what goes in them. Do not enter special categories of personal data such as health, religion or ethnic origin, or personal data that is unrelated or unnecessary for the purpose. If you enter data about children (e.g. a student's name or class), informing the parent and obtaining their explicit consent where needed is your responsibility as the data controller.

If I switch on the AI automated task, who is responsible for what?

You are the data controller for your own customers and leads. Informing these people that their conversations are processed by AI and that conversation text is sent to the AI provider (Anthropic via OpenRouter, United States), which is a cross-border transfer, and obtaining their explicit consent where needed, is your obligation. The consent the company owner gives in the panel does not replace these people's explicit consent. Conversations may contain special categories of personal data such as health data; you need to assess whether this creates additional obligations. The task does not run without the company owner's consent and can be switched off at any time. Every change the AI makes is recorded in the status history and the audit trail; records already converted to customers are not changed.

What happens to my data when the subscription ends?

When the contract ends you get time to export your data. After that period it is deleted from the live system; copies in backups disappear as the backup cycle completes.

Do you use my data for your own purposes?

No. We process tenant data only to provide the service, on your instructions. We do not use it to train AI models or for marketing.

Related

Request a data processing agreement

Send us your company details and we will send you the draft agreement.

Send a request