GDPR & DATA PRIVACY COMPLIANCE STATEMENT

Privacy Policy & Data Protection Statement

Last Revised: August 2, 2026 | Data Privacy, Security Protocols & Processing Terms

Legal Notice: Data Controller & Data Processor Declaration

This Privacy Statement is executed pursuant to General Data Protection Regulation (GDPR - EU 2016/679). İri CRM (Berke İri) operates as a "Data Controller" regarding direct platform subscribers, and as a "Data Processor" regarding end-customer/patient data uploaded to the software by registered clinic clients.

1. Data Controller Identification

İri CRM SaaS platform, cloud infrastructure, and software products are owned and operated by Berke İri ("Sole Proprietorship", "We", "İri CRM").

  • Legal Business Name: Berke İri (İri CRM)
  • Official Website: https://iricrm.com
  • Official Email: [email protected]
  • Headquarters: TOROS MAH. PINARBAŞI CAD. HACI GÖÇMEN APT NO: 13 İÇ KAPI NO: 7 KONYAALTI / ANTALYA, TURKEY

2. Categories of Personal Data Collected & Methods

In the course of providing SaaS operations, the following data categories are processed automatically or via user input:

A. Client Account Data

First/Last Name, Company Title, Corporate Email, Phone Number, Encrypted Password (Hashed), Billing & IBAN details.

B. System & Log Security Data

IP Addresses, Access Logs, Active Sessions, Browser Specifications, Device Hardware Identifiers.

C. Financial Transaction Data

PayTR Online POS Transaction ID (OID), Payment Status, Plan Invoices. (Credit Card numbers are NEVER stored on İri CRM servers).

D. API Integration Telemetry

Meta Business / WhatsApp Cloud API access tokens, Messaging Logs, Template Identifiers, Automation Execution Rules.

3. Limitation of Liability: Data Processor vs Data Controller

Enterprise clients, clinics, and agency accounts using İri CRM act as the SOLE DATA CONTROLLER for all patient, lead, and customer data uploaded into their isolated accounts.

  • Clients are solely responsible for obtaining explicit consent from end-customers pursuant to GDPR Article 6 & 9.
  • İri CRM acts exclusively as a cloud infrastructure DATA PROCESSOR.
  • İri CRM shall not be held liable for any unauthorized data collection, spam violations, or lack of consent committed by client accounts. Clients agree to fully indemnify İri CRM against all third-party privacy claims.

4. Lawful Basis for Data Processing (GDPR Article 6)

Personal data processing is strictly conducted under the following lawful bases:

  • GDPR Art. 6(1)(b): Necessary for the performance of the İri CRM Master SaaS Contract.
  • GDPR Art. 6(1)(c): Compliance with legal obligations under commercial and tax legislation.
  • GDPR Art. 6(1)(f): Legitimate interests pursued by İri CRM to maintain server security and prevent fraudulent access.

5. Third-Party Data Disclosures & Transfers

• PayTR Payment Gateway: For executing encrypted online POS subscription transactions.

• Meta Platforms Inc. / WhatsApp Cloud API: For routing outbound/inbound messaging triggers.

• AWS & Hostinger Cloud: For hosting encrypted database clusters and file storages.

• Legal Authorities: Pursuant to official judicial sub-poenas or court orders.

6. Your Data Protection Rights Under GDPR (Articles 15-22)

Under GDPR, data subjects maintain the right to access, rectify, request erasure ("Right to be Forgotten"), restrict processing, and request data portability. Official enquiries can be submitted to [email protected].

7. Account Deletion & Data Retention Policy (Google Play Compliance)

In accordance with Google Play's User Data & Account Deletion Policy and GDPR Article 17 ("Right to Erasure"), users have the right to request deletion of their accounts and associated data.

A. In-App Deletion: Business Administrators can sign in, navigate to Settings > Business & Profile, and click "Delete My Account and Associated Data". Enter the 6-digit OTP code sent to your registered email along with your password to confirm.

B. Web / Email Deletion Request: If you cannot access the app, you can submit a deletion request from your registered email address to [email protected] with the subject "Account Deletion Request". Requests are processed within 48 hours.

C. 30-Day Grace Period: Upon confirmation, your business account is deactivated and placed in a 30-day grace suspension. You may sign back in at any time within this 30-day window to cancel deletion and instantly restore your account.

D. Data Retention & Erasure Details: After 30 days, all client records, appointments, chat messages, staff logins, and integration tokens are permanently and irreversibly purged from our database. Only mandatory accounting and financial invoice records are preserved as required by tax and commerce laws.

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