This page brings together the services we use when processing businesses' data in UPPU (called Customer Data in the Terms of Service) and the role of each. The binding provisions are clauses E.7 and E.8 of the Data Processing Annex; in the event of a conflict, the Annex prevails.
1. In short
- Customer Data is processed and stored in our own data center in Istanbul, on servers managed by UPPU. We do not use a cloud or hosting provider to host this data.
- WhatsApp, Messenger and Instagram messages pass through Meta's infrastructure; our copy, media files and backups stay in Istanbul. The business connects these channels with its own Meta account and by accepting Meta's terms directly; Meta is not a sub-processor of UPPU.
- Service emails (verification, invitation and alert emails) are sent through mail.uppu.net; these emails do not contain people's names or message contents.
- We use no third-party analytics, tracking, error-tracking or CAPTCHA services in the panel or the chat widget.
2. Services and their roles
| Service | Role | Data processed |
|---|---|---|
| UPPU platform and data center (Istanbul, Türkiye) | The service itself; not a sub-processor. The servers are managed by UPPU | All Customer Data: messages, media files, contact identifiers, consent records and backups |
| Email delivery (mail.uppu.net) | Sending service emails | Panel users' email addresses and the content of service emails; people's names and message contents are not included |
| Meta Platforms Ireland Ltd. and Meta Platforms, Inc. (abroad) | Provider of the WhatsApp, Messenger and Instagram channels; a direct contractual party of the business, not a sub-processor of UPPU | The business's messages and media on these channels, recipient identifiers, read receipts and template definitions |
Data sent to the webhook addresses defined by the business, and data retrieved with the business's API keys, goes to the business's own systems; the business decides the recipient. These systems are not sub-processors of UPPU.
The Facebook JavaScript SDK is loaded on the WhatsApp, Messenger and Instagram connection pages of the panel; this concerns the data of the user making the connection, not Customer Data (Privacy Policy 7). The uppu.net website is served by a separate hosting provider and contains no Customer Data (Privacy Policy 4.1).
3. Transfers abroad
UPPU stores Customer Data in Türkiye. On the WhatsApp, Messenger and Instagram channels connected by the business, messages pass through Meta's systems abroad because that is how these channels work. Informing people about the use of these channels and the obligations under Article 9 of the KVKK lie with the business as data controller; UPPU provides the necessary information on the business's request (Data Processing Annex E.8).
4. Changes and objections
We inform our customers at least 30 days before using a new sub-processor that will access Customer Data, and we update this page. If the customer objects on reasonable grounds, it may terminate the Terms of Service (Data Processing Annex E.7).