Data Processing Agreement
Effective September 24, 2026
When you use Medlar, you decide what work gets done and on which data — you are the controller. We carry that work out on your instructions, so for the personal data inside it we — Buğra Kaan Alp, a sole proprietor in Türkiye, who operates Medlar — are the processor. This page sets out the terms of that arrangement.
It forms part of the Terms of Service for customers who use Medlar to process personal data. If your organization needs to discuss additional terms, email hello@medlar.app.
1. What we process, and why
Only what the work needs. When you brief the team, the relevant content of your connected accounts — an email thread, a calendar entry, a spreadsheet range, a CRM record — is read in order to carry out that request, and the result is written back where you approved it.
If you open a customer case, the case keeps, inside your workspace, your customer's email address, the store and order reference, the order's status and payment state as last read, the reply target you chose, and the case's history. An open case is kept while it is open; once resolved, it follows your workspace's history retention and is removed by history deletion. Every case is included in a workspace export.
We do not decide the purpose. Every processing operation traces to an instruction you gave: a message you sent, or a scheduled task you created. The audit trail on each run is the record of exactly which data was touched and what was done with it.
2. Duration
We process for as long as your workspace exists. History deletion removes eligible run content and its stored activity, subject to workspace history-deletion holds. Some audit metadata, governance, routing, usage and billing records remain outside that deletion; deleting history is not complete workspace erasure. See the privacy policy for retention periods, and section 7 below for deletion on request.
3. Our obligations
- We process only on your documented instructions, including for transfers.
- Everyone with access is bound by confidentiality, and access is limited to the people who need it to run and support the service.
- We keep the security measures in section 6 and review them as the product changes.
- We help you meet your own obligations: responding to data subject requests, security assessments, and prior consultation with a regulator where one applies.
- We tell you without undue delay if we believe an instruction of yours breaks data protection law, rather than carrying it out quietly.
4. Sub-processors
We use the providers below to run the service. Each is bound by a data processing agreement for the purposes described below. Each provider's own terms and data-processing documentation govern its processing.
We keep this list current and will provide reasonable notice of a material new sub-processor where required by applicable law or an agreed enterprise contract. Contact us before placing regulated or unusually sensitive data in the service if you need a provider-specific assessment.
5. International transfers
The database that holds your workspace — accounts, runs, and the audit trail — runs in the EU (Frankfurt). That part we operate ourselves, so we can state it plainly.
Our providers may process data in multiple jurisdictions, including the European Economic Area, the United Kingdom, and the United States. Where applicable, international transfers must use a lawful transfer mechanism supplied by the relevant provider, such as Standard Contractual Clauses, a UK addendum, or an adequacy framework.
We won't list a jurisdiction per provider here that we haven't verified: each provider's own data-processing terms, reachable from its site linked above, state where it processes, and we would rather point you at the authoritative source than restate it and be wrong.
6. Security
- Connection tokens are encrypted at rest with AES-256-GCM and never stored in plain text.
- Data is encrypted in transit (TLS) throughout.
- Credentials are never given to the AI. Any call that needs one runs on our own servers, outside the model's sandbox — the model asks for an action, it does not hold the key.
- Workspace administrators choose the approval policy. Connections begin read-only; actions may be individually approved or allowed by policy, and the decision is recorded.
- Access to production is limited and authenticated; workspaces are isolated by organisation.
7. Deletion and return
You can delete individual runs, disconnect apps, export workspace data, and use the account or organization controls available in the product. On a verified deletion request, we remove customer content from active systems within a reasonable period, except where we must retain records to meet a legal obligation. Backup and provider-side copies expire under the applicable retention schedules.
Ask at hello@medlar.app and we will export what we hold before deleting it.
8. Audits
We will provide reasonably available information needed to assess these controls. Medlar does not currently claim SOC 2 or ISO 27001 certification.
9. Personal data breach
If we become aware of a personal-data breach affecting customer data, we will notify the affected controller without undue delay as required by applicable law and provide the information reasonably available about impact, mitigation, and recommended next steps.
10. Precedence and contact
This agreement forms part of the Terms of Service. Where it conflicts with them on the processing of personal data, this page wins.
Data protection contact: hello@medlar.app.
