Commercial Electronic Messages and İYS

This notice explains the parties' obligations for the SMS, WhatsApp and email messages sent through the Dualyx Appointment platform (the "Platform"). It is based on Law No. 6563 on the Regulation of Electronic Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages.

Version: v1 · Last updated: 4 September 2026

1. Who counts as the sender

When a message is sent to a customer through the Platform, the service provider — that is, the sender — is the business. The business decides the content of the message, the recipient list, the timing and the channel.

[LEGAL ENTITY NAME] provides the technical infrastructure that delivers the message. Obtaining consent, retaining the consent record, registering with İYS (the Message Management System) and honouring the right to opt out are the business's obligations.

2. Transactional notifications versus commercial messages

The Platform can produce two kinds of message:

Transactional notifications. Notifications that an existing appointment has been created, changed or cancelled; appointment reminders; appointment confirmation requests; and post-appointment feedback requests. These messages relate to performance of the service and carry no marketing content.

Commercial electronic messages. Messages with marketing content such as promotions, campaigns, discounts and greetings, which can be created with the Panel's bulk and scheduled sending functions.

Which category a message falls into is determined by its content. Adding a marketing statement to a transactional notification turns that message into a commercial electronic message. Making that assessment and shaping message content accordingly is the business's responsibility.

3. The business's obligations

Before sending a commercial electronic message, the business must:

• obtain the recipient's prior consent or rely on one of the exceptions provided in the Law,
• record the consent in İYS and check the recipient's İYS status before sending,
• state its identity, trade name and contact details clearly in every message,
• offer an easy and free-of-charge opt-out in every message,
• process opt-out notifications into İYS without delay and stop sending to recipients who have opted out,
• retain consent and opt-out records for the period prescribed by legislation.

The business is responsible for administrative sanctions and damages arising from a failure to meet these obligations.

4. Tools the Platform provides

• İYS settings. Turning İYS use on or off in the SMS settings and choosing which İYS list (individual / merchant) sending runs against.
• Sender name (header). Using the sender header registered for the business with its provider.
• Templates. Managing message content as templates and using variables. The business edits template content; content a business has edited is not overwritten by updates.
• Channel and scope selection. Turning appointment creation, change, cancellation, reminder and feedback notifications on or off individually, and choosing the reminder lead time and channel.
• Sending records. A record of who each message was sent to, over which channel, with what content, and its delivery state, with a view of messages that could not be delivered.

These tools make it easier for a business to meet its obligations, but they do not verify or guarantee the existence of consent on behalf of [LEGAL ENTITY NAME].

5. Channel rules

SMS. Sending runs through the provider account (İleti Merkezi or Verimor) configured for the business. Registration of the sender header, balance, sending limits and the provider's content rules bind the business.

WhatsApp. Sending runs over the Meta WhatsApp Cloud API and is subject to Meta's commercial policies, template approval rules and messaging window restrictions. Messages cannot be sent with templates Meta has rejected or not approved. Meta may restrict a number following user complaints.

Email. The Platform's email infrastructure is primarily for account and service messages (verification, password reset, support replies).

6. Relationship with data protection

Consent for a commercial electronic message does not replace explicit consent under KVKK. A business must separately meet its KVKK obligations when processing recipients' contact data. That relationship is set out in the Data Processing Agreement.

7. Abuse

Sending commercial electronic messages to recipients who have not consented, using misleading sender information, or failing to honour the right to opt out is a breach of the Terms of Use. In such cases [LEGAL ENTITY NAME] may restrict the messaging feature or suspend the account.

8. Contact

Send questions to info@dualyxlabs.com or through the support screen in the Panel.