Effective Date: January 2018 Last Updated: September 2025
1. Introduction
This Privacy Policy describes how YTS-Agents, a subsidiary of Perle Marketing (France), collects, uses, discloses, transfers, and protects personal data in connection with:
Content Data: files and datasets uploaded for automation purposes.
Communication Data: emails, support tickets, chat logs.
We do not knowingly process special categories of data (racial origin, health, religious belief). If such information is accidentally received, it will be deleted immediately.
6. Purpose of Processing & Legal Basis
Purpose
Examples
Legal Basis (GDPR Art. 6)
Service delivery
Implementing automations, analytics, dashboards
Contract performance (b)
Communication
Responding to inquiries, support, proposals
Legitimate interest (f)
Marketing
Newsletters, social updates (opt-in only)
Consent (a)
Billing
Preparing invoices, tax compliance
Legal obligation (c)
Security
Monitoring, backups, threat detection
Legitimate interest (f)
Recruitment
Processing job applications
Consent (a) / Pre-contractual steps (b)
7. Methods of Collection
Forms on the website (contact, quotation, newsletter).
Direct email or phone communication.
Project onboarding documents and contracts.
Automated data collection via cookies and analytics scripts.
Third-party integrations (n8n workflows, API connections, CRM tools).
8. How We Use Your Data
To register you as a client and manage contracts.
To configure AI and automation solutions.
To communicate status updates and technical reports.
To create KPI dashboards and performance analytics.
To comply with financial and legal obligations.
To improve our website and service offerings.
We will never sell or lease personal data to third parties.
9. Cookies and Tracking Technologies
Types used:
Essential (session management, security)
Analytics (Google Analytics 4, Matomo)
Marketing (Meta Pixel, LinkedIn Insight Tag)
Retention: analytics cookies 26 months maximum. Users may manage preferences through our cookie banner or browser settings.
Obtain confirmation of processing and a copy of your data.
Rectification
Correct inaccurate or incomplete data.
Erasure
Request deletion when data is no longer necessary.
Restriction
Temporarily limit processing.
Portability
Receive data in machine-readable format.
Objection
Object to processing for legitimate interest or marketing.
Withdraw consent
For email marketing or cookies at any time.
Response time: within 30 days (GDPR) or 45 days (KVKK). If unsatisfied, you may lodge a complaint with CNIL (France) or KVKK Authority (Türkiye).
15. Children’s Data
Our services are not intended for individuals under 16 years of age. We do not knowingly collect such data. If identified, it is deleted immediately.
16. Processing on Behalf of Clients (Data Processor Role)
When providing automation services, YTS-Agents acts as Data Processor, and the Client is Data Controller.
We process only on written instructions from the Client.
All personnel sign confidentiality agreements.
We do not sub-process without authorization.
We assist Clients with data-subject requests and breach notifications.
We delete or return data upon project termination.
These obligations are formally governed by the Data Processing Agreement (Annex E).
17. Sub-Processing & AI Technology Use
When using AI tools (OpenAI API, Jasper.ai):
Only pseudonymized and non-sensitive content is shared.
Processing occurs under each provider’s DPA and EU SCCs.
No training data retention beyond session is authorized.
18. Data Breach Procedure
If YTS-Agents becomes aware of a breach:
Incident recorded immediately in security log.
Impact analysis within 24 hours.
Notification to Controller and Authority within 48 hours (GDPR Art. 33).
Remediation and prevention report issued within 72 hours.
19. Automated Decision-Making and Profiling
YTS-Agents does not engage in automated decision-making that produces legal effects on individuals. AI models used for workflow optimization operate only on business data for efficiency purposes.
20. Third-Party Links
Our website may contain links to external sites (Google, LinkedIn, Meta, etc.). We are not responsible for their content or privacy policies. Please review them independently.
21. International Marketing & Opt-Out
Email marketing is sent only with explicit consent (opt-in checkbox or double opt-in email). Unsubscribe links are included in all campaigns. Marketing preferences can also be updated by contacting privacy@yts-agents.com.
22. Employee and Freelancer Data
We process limited data for human-resources purposes (recruitment, contracts, payments). Access is restricted to HR personnel only and retained for the duration of employment + 5 years.
23. Record of Processing Activities
YTS-Agents maintains an internal Record of Processing (Article 30 GDPR), updated quarterly and available to supervisory authorities upon request.
24. Data Protection Officer (DPO)
Name: [Appointed DPO or External Advisor] Email:dpo@yts-agents.com Postal: 2 Allée des Bosquets, 94800 Villejuif/Paris, France
25. Updates to This Policy
We may update this Privacy Policy periodically to reflect changes in law or technology. Updates take effect immediately upon publication on our website. Substantial changes will be communicated via email notice to clients.
26. Governing Law and Jurisdiction
This Policy is governed by French law and GDPR principles. For Türkiye-based processing, KVKK Law No. 6698 applies. Disputes will first be subject to amicable settlement and failing that, to the exclusive jurisdiction of the Commercial Court of Paris or Istanbul Courts (as mutually agreed).
27. Acknowledgment of Understanding
By using our website or services, you acknowledge that you have read, understood, and accepted this Privacy Policy and consent to the processing of your data in accordance with it.
✅ Summary Table of Key Facts
Topic
Summary
Controller
YTS-Agents / Perle Marketing, Paris
Data Retention
Up to 10 years (depending on category)
Transfers
EU ↔ Türkiye under SCCs
Rights
Access, Rectify, Erase, Port, Object, Restrict
Breach Notice
Within 48 hours
AI Tools
Used only with data minimization and anonymization
