Privacy Policy

Last updated: September 21, 2026

1. Scope and data controller

SECRETARY is a subscription service consisting of an AI work assistant installed on your Windows computer and a web panel used to manage it. This document is both a privacy policy and a privacy notice under Article 10 of Turkish Personal Data Protection Law No. 6698, known as KVKK. It explains which data is processed when you use the panel and desktop software, where and how long that data is stored, who receives it, and which rights you have.

The business providing the SECRETARY service is the data controller for your account data. For any question or request concerning personal data, contact us at: hi@secretary.sh

We consider a clear and auditable account of data flows a core responsibility. This document therefore explains separately which data is stored permanently and which content is retained only temporarily while an operation is in progress.

2. Where data is processed

3. Data controller and processor roles

We are the data controller for your account data, including your identity, contact details, payment and usage records, computer information, and support correspondence.

The position is different for your business data. Documents, emails, calendar entries, WhatsApp and Telegram conversations, contact records, address book entries, and data collected from websites by Agent on your instructions belong to your business. The people in this data, including your customers, clients, patients, suppliers, and employees, have a relationship with you rather than with us. For this processing, you are the data controller and we act as the processor, solely on your behalf and according to your instructions. We do not use this data for our own purposes, sell it, or share it for advertising.

You are therefore responsible for having a valid legal basis under Articles 5 and 6 of KVKK, informing these people, obtaining explicit consent where required, responding to their requests, and sharing only data that is genuinely necessary when creating a task. If one of your contacts applies directly to us, we will forward the request to you and help you respond.

Special categories of personal data. Your documents and messages may contain health, biometric, religious, criminal conviction, or other sensitive data. We do not process this data for our own purposes. The service does not separately identify, classify, or protect it, so it follows the same paths as other business data. If you process such data with Agent, you are responsible for meeting Article 6 requirements under KVKK and applying any additional safeguards. We recommend excluding documents containing this data when it is not necessary.

4. Account and service data

Identity. You sign in with Google. We receive your name, email address, and basic profile information provided by Google, such as the profile image link. We request only profile and email permissions. We do not see your password, you have no password stored with us, and this sign-in does not give us access to your Gmail inbox. We also store the business name and language preference entered in the panel.

Contact details. You provide the WhatsApp number or Telegram chat ID used for notifications and, when both are connected, select your preferred channel.

Subscription and payment. We store your plan, subscription status, renewal date, payment and refund amounts and dates, and the order number from the payment provider. Your card details never pass through our systems. When you are sent to the payment page, your email address is added to the link and the incoming payment is matched to your account through that email address.

Computer information. For every computer where Agent is installed, we store the Windows computer name, your label, operating system type, installed Agent and component versions, component version summaries, available capabilities, installation and repair error text, latest connection and sync times, and the access key for that computer. We also keep a short event log for each computer, such as connected, stopped, or repair attempted.

Connection records. The IP address and port recorded when you create the account are retained unchanged. The IP address, port, and time of your latest panel access are refreshed at each sign-in. The address used by your computer to connect to our server is used in short-lived counters that limit misuse.

Usage and charge records. For every AI or paid tool request, we record the time, originating computer, model, amount of processed text, numerical size estimates for parts of the request, amount charged to your account, and result. These records do not contain the content of your messages or documents. The only exception is technical error text returned by a provider when a request fails, limited to 2,000 characters.

Task definitions. We store the text entered in the task setup wizard, the generated draft, your corrections, task rules, task folder, and selected settings.

Notifications. The full text of every message sent to your phone or Telegram account, the attachment name when applicable, and the sending time are stored on the server. Messages prepared by Agent during a task and held until the run finishes are also stored in full.

Support correspondence. Messages you send in panel support chat and the responses are stored. An AI model answers first. If the model cannot resolve the issue, it offers to transfer the conversation to our team. If you agree, a short summary, your name, and email address are sent to the WhatsApp or Telegram notification channel used by team administrators, and a team member takes over. We record who took over and what they wrote. Recent chat messages are sent to the model to create an AI response, but your account details are not included.

5. Records stored during task runs

Agent reports its actions to the server while running and after completing a task. Every run card shown in the panel is built from this record. The record contains the following text derived from your business data:

When a run is complete, the server uses this record to generate a closing report and, where necessary, a missing-items list. Your computer writes both to the task folder. These records are retained while your account remains open. Retention and deletion are explained in Section 18.

6. Content processed temporarily

The following content passes through our server to complete an operation but is not permanently stored beyond the temporary periods stated below:

During their one-hour lifetime, video and image files may be served through an unlisted, randomly generated link that does not require sign-in. Some channels need to retrieve files from our server this way. The link works only for video and image file types.

7. Connected application operations

Operations in Gmail, Calendar, Slack, and similar connected applications run through our server. SECRETARY sends the operation and required parameters to the server. Our server performs the operation through Composio, our integration provider, and receives the result. Email bodies, attachments, and calendar entries therefore pass through our server while an operation is in progress.

We do not store application passwords or access tokens. When you connect an application, its permission screen opens in your browser and authorization tokens are stored by Composio. We send Composio your SECRETARY customer number to identify the account and the parameters needed for each operation, such as recipient, subject, body, or attachment.

8. WhatsApp and Telegram

The session remains on your computer. WhatsApp and Telegram are used through Agent on your computer with your own accounts. Incoming messages are received there and documents are saved there. Messages passing through these channels are also subject to the terms of the relevant platform. WhatsApp does not provide an official business interface for this service, and any restrictions applied to your account are decided by the platform.

A separate Agent handles WhatsApp messages. The Agent that runs your tasks is separate from the Agent that handles WhatsApp conversations. Each contact has a separate conversation session, and the WhatsApp Agent can use only a restricted set of tools.

Who can send accepted messages. If task scope is limited to your contacts, messages from numbers outside your contact list and your own notification number are rejected by the Agent engine on your computer. They are not processed, sent to AI, or recorded. If scope is set to everyone, messages from any number are accepted. Group messages are not processed.

Collect mode. Documents received from your contacts are copied on your computer to a sender-specific subfolder inside the task folder. The folder name is based on the saved name or number and the WhatsApp name. Message text is normally not sent to AI in this mode. In the exceptional case that the engine bypasses this rule, the message may still reach the model, but no reply is sent.

Reply mode. Agent replies to messages from your contacts according to the task instructions and by reading the source folder you selected. The contact message, conversation history, and source content pass through our server to the AI model and are not stored on the server. Before sending, Agent waits for a random few seconds and quotes the message being answered. Agent messages you when a matter needs your attention.

Information reported to the server. For each incoming message, your computer reports the sender number, WhatsApp name, names of saved files and the subfolder, and names and reasons for files that could not be copied. Message text is not sent. The server stores only the latest document arrival time for the matching contact. If a document from a number not on your list passes the engine gate, you are notified. That notification includes the number and remains in notification records. Files that could not be copied are also reported by name. Gate decisions are reported only as counts and contain no phone number or message content.

Selecting contacts from the address book. When WhatsApp is connected, Agent keeps a copy of contact data supplied by WhatsApp only on your computer, limited to 4,000 saved names and numbers. This copy is uploaded to our server only when you ask to import contacts in the panel. The upload contains at most 2,000 names and numbers for people who have a saved name and are not already contacts. The list is deleted from the server when you complete or cancel the selection, and only selected people remain as contacts. If you leave without choosing, the list remains until your next import or selection.

When you disconnect. Agent signs out of the WhatsApp session on your computer, removing it from the linked devices list on your phone. After a successful sign-out, the WhatsApp identity folder on your computer is deleted completely. Only success status and a short reason are reported to the server. If sign-out fails, the panel explains what to do on your phone.

9. Your contacts

A server record is created for each person you add as a contact. It includes the name, an optional tax or Turkish identity number, your notes, identifiers used to recognize the person, such as a phone number, email, WhatsApp ID, or file number, a label for each identifier, and its source. The record also stores the latest document arrival time.

You are the data controller for information about these people. The responsibilities in Section 3 also apply to these records.

10. Web operations and browser data

When your tasks require it, Agent visits websites on your instructions, collects information such as tables and lists, and downloads files. It uses a dedicated Agent browser profile on your computer rather than your personal browser.

Visited sites are subject to their own privacy policies and terms. You are responsible for determining whether automated collection complies with the site terms and applicable law, and for having a legal basis when collected information contains personal data.

11. Access and changes on your computer

Agent runs with the permissions of your user account and can access files available to you. It is not confined to a sandbox because it works with actual documents in your folders. Every change made by installation is listed in Section 3 of the Terms of Use. We recommend reading that section before installation.

The following items may be deleted from your computer by a server instruction: temporary files left by a completed run in the delivery folder and Agent workspace, whose names are reported by the computer and selected individually on the server rather than guessed by Agent; the WhatsApp identity folder when you disconnect; and Agent tasks, channel sessions, and the browser profile when you remove a computer from the panel. The closing report and missing-items list written to your delivery folder are not deleted.

12. Processing purposes and legal bases

We collect and process account data through fully or partly automated means, including the panel, Google sign-in, Agent on your computer, payment-provider notifications, and support chat. Under Article 5 paragraph 2 of KVKK, we process it for the following purposes and legal bases:

We do not rely on explicit consent for these operations. Promotional commercial electronic messages are subject to the separate rules in Section 16. We process business data as a processor and according to your instructions. You provide the legal basis for that data, as explained in Section 3.

13. Data sharing and international transfers

We use the following providers to deliver the service. Each receives only the data necessary for its role:

WhatsApp and Telegram are not our providers. You use these channels from your own computer with your own accounts, and messages travel between your computer and those platforms.

Apart from these disclosures, personal data is shared only to the extent required by a lawful request from an authorized public authority. We do not sell or rent your data or share it for advertising.

International transfers. All providers listed above are established outside Türkiye and process data on servers outside Türkiye. Using the service therefore requires account and business data to be transferred abroad. Transfers are made under Article 9 of KVKK, relying first on an adequacy decision by the Board or, when none applies, an appropriate safeguard listed in the law, such as standard contractual clauses. When these cannot be provided, a transfer is limited to the occasional situations permitted by law. Contact us for information about safeguards used for a transfer.

14. Use of AI and automated decisions

AI models are central to the service. Content sent to models may include task instructions, which can contain a contact list, documents, emails, calendar entries and webpages read by Agent, WhatsApp conversations in Reply mode, documents read as images, image-generation prompts, and text entered in the task setup wizard or support chat.

Model training. We do not use your data to train AI models. OpenRouter states in its privacy policy that it does not use inputs and outputs for model training. Each model provider reached through OpenRouter has its own retention and training policy, and these policies vary by provider.

Errors. AI can make mistakes. You are responsible for reviewing Agent output before relying on it for a decision.

Automated operations. Some account outcomes occur automatically. Agent stops when monthly usage is exhausted, payment fails, or a subscription ends. Requests are rejected when call or spending limits are exceeded. Agent pauses for your approval when an operation requires it. Under Article 11 paragraph 1 subparagraph g of KVKK, you may object to an adverse outcome caused solely by automated analysis of your data. Send an objection to hi@secretary.sh for review by a person.

15. Authorized team access

To provide support and diagnose faults, authorized team members with administration access can view account details, usage and payment records, run records, messages sent to your phone, computer event logs, and support correspondence. When necessary, they can enter your panel on your behalf. Every administration change and every entry to and exit from your panel on your behalf is written to an audit record with the identity of the team member. You may request this record.

16. Emails and commercial electronic messages

We send emails required to operate the service, including alerts when usage is low or exhausted, subscription renewal reminders, and mandatory service notices. These messages are necessary for the subscription relationship. Our team may also send account holders service announcements by bulk email.

Promotional or campaign-related commercial electronic messages are sent in accordance with Turkish Law No. 6563 on the Regulation of Electronic Commerce and related legislation, either with your consent or where the law does not require consent. You may opt out of commercial electronic messages at any time and without charge by writing to hi@secretary.sh.

17. Security

Database fields are not separately encrypted at application level. Data is protected by the access controls described above and the security measures of the hosting infrastructure. No information system can provide absolute security, so we cannot promise uninterrupted or error-free protection.

Data breaches. If we learn that personal data has been unlawfully obtained by another party, we will notify the Turkish Personal Data Protection Board as soon as possible and no later than 72 hours, and affected people within a reasonable period, in accordance with Article 12 of KVKK and Board decisions. If the breach affects your business data, we will notify you without delay so you can meet your own reporting duties as data controller.

18. Retention periods and deletion

Account information, task definitions, run records, notifications and held messages, contact records, support correspondence, usage records, computer event logs, processed-item ledgers, and administration audit records are retained while your account remains open so we can provide the service. Use the application process below to request deletion.

The following items are deleted automatically:

When you remove a computer from the panel, it is removed from the service and cleans itself on its next connection. Tasks are deleted, channel sessions are closed, and the browser profile is reset. Historical records for that computer remain in the panel.

When you close your account, access ends, your computers are removed from the service, tasks stop, the sign-in address is disabled, and the Google account connection is removed. Deletion of records requires a separate request. To prevent subscription renewal, you must cancel through the payment provider.

To request deletion of your data, write to hi@secretary.sh. We will conclude the request within 30 days and confirm in writing what was deleted. Records that must be retained by law, such as payment and invoice records, and records necessary to protect a right are kept for the applicable period and then deleted, destroyed, or anonymized.

You can remove authorization for connected applications one at a time by selecting Disconnect in the panel, and you can also revoke access in the security settings of each application. Files created or collected by Agent on your computer belong to you and remain on your computer under your control.

19. Your rights under KVKK and how to apply

Under Article 11 of KVKK, you have the right to learn whether personal data is processed; request information if it is; learn the purpose of processing and whether data is used consistently with that purpose; know the third parties receiving it in Türkiye or abroad; request correction of incomplete or inaccurate data; request deletion or destruction under the conditions in the law; request notice of correction, deletion, or destruction to third parties that received the data; object to an adverse result caused by analysis solely through automated systems; and claim compensation for damage caused by unlawful processing.

How to apply. Under the Communiqué on Procedures and Principles of Application to the Data Controller, you may apply in writing, by registered electronic mail known as KEP, secure electronic signature, mobile signature, or from the email address registered in our system to hi@secretary.sh. Include your full name and, for a written application, signature; Turkish identity number if you are a citizen of Türkiye, or nationality and passport or other identity number if you are not; residential or business address for notices; email address and phone number for notices when available; and the subject of the request. We may request additional information to verify your identity.

We will conclude your application free of charge as soon as possible and no later than 30 days, depending on its nature. If processing creates an additional cost, the fee set by the Turkish Personal Data Protection Board may apply. If the application is rejected, the response is inadequate, or no timely response is provided, you may complain to the Board within 30 days of learning the response and in all cases within 60 days of the application.

Requests concerning data for which you are the controller, such as data about one of your contacts, should be submitted to you. If we receive such a request, we will forward it and help you respond.

20. Cookies

Our website and panel use only cookies that are essential to operate the service. They are used for contract performance and our legitimate interest in security. Under the KVKK Guidelines on Cookie Practices, explicit consent is not required for these essential cookies:

The panel also uses browser session storage to remember which channel tab you left open. This information remains only in your browser and is deleted when the tab closes.

We do not use analytics, advertising, or marketing cookies, and we do not run third-party tracking tools. Page assets, including fonts, load from our own server. When you sign in with Google, Google uses cookies on its own site under its own policy. You may delete or block essential cookies through browser settings, but the panel will no longer allow sign-in.

21. Users in the European Union and other countries

If you are in the European Union or European Economic Area and the General Data Protection Regulation applies to the service, we process account data under Article 6 based on contract performance, paragraph 1 subparagraph b; legal obligation, subparagraph c; and legitimate interests, subparagraph f. You have rights of access, correction, deletion, restriction, portability, and objection, and may complain to the data protection authority in your country.

For business data, you are also the controller under the GDPR and we process data on your behalf. Data is processed outside the European Economic Area, including in Türkiye and countries where the providers in Section 13 operate. If an EU representative is appointed under Article 27, contact details will be published in this section. Until then, use hi@secretary.sh for all requests.

22. Children

The service is intended for businesses and adults. It is not offered to anyone under 18, and we do not knowingly collect account data from people under 18. If we identify such an account, we will close it.

23. Changes

This policy is updated when product operation changes, and the date above is revised. If an update materially changes how data is processed, we will send a separate notice before it takes effect.

24. Contact

For any question about this policy, your personal data, or your rights, contact: hi@secretary.sh