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Privacy Policy

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Expansion Strategy

1. Introduction
We (“we,” “our,” or “us”) respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our WhatsApp-based application (the “App”), in full compliance with the EU General Data Protection Regulation (GDPR). By using the App, you agree to the terms of this policy, including our right to commercially exploit all content you exchange through the App.

2. Controller and Data Protection Officer
The data controller responsible for your personal data is:
[Your Company Name]
[Postal Address]
[Email Address]
[Phone Number]

If required by GDPR, our Data Protection Officer can be reached at:
[Name]
[Email Address]

3. Personal Data We Collect
We collect only the information necessary to operate the App and deliver its services:

  • Account Data: Your name, phone number, user ID.

  • Message Content and Media: All messages, images, audio or other files you send or receive via the App.

  • Usage and Diagnostics: Log data, device information, and performance metrics.

4. Lawful Basis for Processing
Under GDPR, we rely on the following legal bases for processing your data:

  • Performance of a Contract: To provide messaging services and customer support.

  • Legitimate Interests: To improve our App, secure our systems, and detect fraud or abuse.

  • Consent: Where required (e.g., optional analytics or marketing communications). You may withdraw consent at any time.

5. Commercial Use of Exchanged Content
By using the App, you grant us a worldwide, royalty-free, perpetual, irrevocable, transferable license to use, reproduce, adapt, publish, distribute, and otherwise commercially exploit all messages and media you exchange through the App, for any purpose, including marketing and product development.

6. How We Use Your Information
We use your data to:

  1. Provide and maintain the App’s messaging features.

  2. Respond to support inquiries and troubleshoot issues.

  3. Analyze usage and improve functionality.

  4. Comply with legal obligations.

7. Data Sharing and Disclosure
We do not sell your personal data. We may share information with:

  • WhatsApp Inc.: To facilitate message delivery.

  • Service Providers: Hosting, analytics, support—under strict confidentiality.

  • Legal Authorities: When required by law or to protect rights.

8. International Transfers
Your data may be transferred to and processed in countries outside the European Economic Area. We ensure appropriate safeguards (e.g., Standard Contractual Clauses) are in place to protect your rights.

9. Data Retention
We retain personal data only as long as necessary:

  • Message Content: Up to 30 days for delivery, then deleted.

  • Account and Logs: Up to 12 months for support and compliance.

10. Your Rights under GDPR
You have the right to:

  • Access, correct, or delete your personal data.

  • Restrict or object to processing.

  • Receive your data in a portable format.

  • Lodge a complaint with a supervisory authority.

To exercise these rights, contact us at [Email Address]. We will respond within one month.

11. Security Measures
We implement appropriate technical and organizational measures (encryption in transit and at rest, access controls) to protect your data against unauthorized access, alteration, or destruction.

12. Children’s Privacy
The App is not intended for children under 16. We do not knowingly collect data from minors. If you believe we have done so, please contact us for prompt deletion.

13. Changes to This Policy
We may update this Privacy Policy. We will notify you of material changes by updating the “Last updated” date and, where appropriate, by providing a more prominent notice.

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