Hey There

CIRCLE 96 LLP WhatsApp Bot Privacy Policy1. IntroductionCIRCLE 96 LLP ("Circle 96", "we", "us", "our"), UEN T12LL1626J, with registered office at ONE Raffles Quay, Level 49 NORTH TOWER, Singapore 048583, provides a conversational WhatsApp Business bot ("Bot") via the Meta Business Platform. This policy explains how we collect, use, disclose, and store personal data in compliance with:- WhatsApp and Meta Platform Policies,- Singapore's Personal Data Protection Act (PDPA), and- Applicable international laws (e.g., GDPR where relevant).2. Scope & ConsentBy opting in to receive messages via WhatsApp, you expressly consent to our collection, use, and processing of your personal data described herein. You may withdraw consent at any time by texting "STOP" in WhatsApp or contacting us.3. Information We Collect- User-provided information: phone number, name, preferences, messages, and media you share within the Bot.- Metadata: timestamps, message IDs, message frequency, and basic analytics.- Technical data: device type, OS version, IP address (if retrieved via integration).- We do not access your end-to-end encrypted message contents—these remain private between you and Meta.4. Purpose of UseWe use your data to:- Send messages and responses you request,- Provide customer support,- Share updates or promotions only if you opt in,- Analyze usage to improve Bot functionality, and- Satisfy legal obligations and prevent abuse.5. Legal Basis & Data MinimizationProcessing is based on your explicit opt-in. We collect only what's necessary to serve you. Sensitive data is handled solely with your explicit consent and minimized wherever possible.6. Data RetentionData is stored only for as long as needed:- Support conversations: up to 12 months (or as required by law),- Marketing consent logs: one year after withdrawal,- Metadata: six months.After these periods, data is securely deleted or anonymized.7. Data Sharing & DisclosureWe may share your personal data with:- Meta – for Bot delivery and functionality; only non-content metadata is shared.- Service providers – cloud infrastructure (SOC 2 certified), analytics vendors, messaging platforms, all under strict contractual obligations.- Regulatory authorities – only if required by law (e.g., court orders, investigations).No data is sold, leased, or used for targeted advertising beyond Bot operations.8. Data TransfersIf personal data is transferred outside Singapore, we ensure foreign recipients uphold comparable PDPA or GDPR standards via binding contracts or other legal mechanisms.9. Security MeasuresWe implement physical, technical, and organisational safeguards, including:- Encryption in transit (TLS) and at rest,- SOC 2-compliant infrastructure,- Restricted, need-to-know access controls, and- Regular security audits and penetration tests.10. User Rights & ControlsYou can:- Access or request correction/deletion of your data,- Withdraw consent or unsubscribe at any time,- Object to or restrict processing,- Lodge complaints with the PDPC, and- Port your data in a structured, machine-readable format.Submit requests via email or WhatsApp.11. Children's PrivacyOur Bot is not designed for users under 18. We don't knowingly collect children's data. If we become aware that a user is underage, we'll delete their data promptly. Parental consent is required where legally necessary.12. Opt-In & Opt-Out Procedures- Opt-in: You must proactively message the Bot or confirm via a separate channel before we contact you.- Opt-out: Reply "STOP" or contact us. After opt-out, all Bot messaging ceases except confirmation messages.13. Updates to This PolicyWe may revise this policy to reflect changes in laws, Bot operations, or Meta requirements. Updates will be posted here with an updated "Last Updated" date. We'll notify you via WhatsApp or email of material changes.14. Contact & ComplaintsFor privacy inquiries, access requests, or complaints, please contact our Data Protection Officer (DPO):Email: contact@circle96.comMailing Address: ONE Raffles Quay, Level 49 NORTH TOWER, Singapore 048583 Attn: DPOWe aim to resolve complaints within 30 business days.