Privacy Policy

1. Scope and responsible entity

This policy explains how GInIEm S.A. ("GInIEm", "we", "us") processes personal data when someone visits giniem.com, requests our services, creates an account, or uses a solution operated by GInIEm, including our shared support system connected to the WhatsApp Business Platform.

GInIEm acts as controller for data collected directly through our website and commercial relationships. When a customer company uses our platform to communicate with its own contacts, that company determines the purposes of the communication and GInIEm processes the data on its behalf and under its instructions.

2. Data we process

Depending on how you interact with us, we may process:

• Contact and business data: name, email, telephone number, company, position, and request content.
• Account data: email, internal identifiers, company or workspace, role, access status, and session records. Passwords are stored as hashes, not readable text.
• Technical data: IP address, browser, device, visited pages, date, time, and security or diagnostic logs.
• WhatsApp Business data: business-account identifiers, telephone number, user identifiers, profile name, messages, attachments, delivery statuses, timestamps, and agent assignments.
• Integration credentials: tokens, secrets, and technical data needed to connect services authorized by the customer company.

3. WhatsApp Business and Coexistence

When a company connects its account through Meta Embedded Signup, we receive from Meta and WhatsApp only the assets and permissions authorized to provide the requested service. If the company uses Coexistence and approves information sharing from the WhatsApp Business app, we may also receive contacts, messages sent from the phone, and up to 180 days of available one-to-one history during onboarding.

The customer company is responsible for notifying its contacts, establishing a valid legal basis, and complying with WhatsApp policies. Meta Platforms and WhatsApp process information under their own terms and privacy policies.

4. How we use data

We process information to:

• Answer inquiries, prepare proposals, and provide support.
• Authenticate users, manage teams, and isolate each company workspace.
• Receive, display, assign, and send authorized communications through the WhatsApp Business Platform.
• Synchronize contacts and history when expressly authorized by the company.
• Protect accounts, prevent abuse, investigate incidents, and maintain operational records.
• Measure and improve the website, our products, and service quality.
• Comply with contractual and legal obligations.

5. Legal bases

Depending on the relationship and applicable law, we process data to perform a contract or pre-contractual request, comply with legal obligations, support legitimate security and service-improvement interests, or based on consent where required. You may withdraw consent without affecting prior lawful processing.

6. Who receives information

We do not sell personal data. We may share necessary information with:

• The customer company and authorized members of its workspace.
• Meta Platforms and WhatsApp to operate the WhatsApp Business Platform.
• Infrastructure, hosting, email, monitoring, analytics, and support providers subject to confidentiality and security obligations.
• Authorities or advisers when required to comply with law, protect rights, or respond to valid legal process.
• A successor entity in a reorganization or business transaction, subject to equivalent protections.

7. International transfers

Some providers may process data outside the country where the individual is located. Where applicable, we use contracts, documented instructions, and other reasonable safeguards to protect information during those transfers.

8. Retention

We retain data while necessary to provide the service, maintain the account, resolve disputes, follow valid customer instructions, and meet legal or security obligations. When the relationship ends, we delete or anonymize information according to valid customer requests, applicable legal periods, and reasonable backup cycles.

The company administering a workspace may establish additional retention requirements for its conversations and is responsible for communicating them to its contacts.

9. Security

We apply company- and role-based access controls, authentication, event logging, credential protection, and technical and organizational measures proportionate to risk. In solutions that store conversations, message content and sensitive credentials are encrypted at rest; production communications are protected in transit.

No system is completely infallible. We investigate incidents and provide legally required notices where applicable. We do not use customer conversations to train general-purpose artificial-intelligence models unless separately, explicitly, and validly authorized.

10. Cookies and measurement

The website may use cookies and measurement tags, including Google technologies, to operate correctly, understand website usage, and measure campaigns. You can limit cookies through your browser. Authenticated services may use strictly necessary cookies to sign you in and protect the session.

11. Rights and data deletion

You may request access, correction, updating, objection, restriction, or deletion, depending on applicable law. If your data belongs to a conversation with a company using our platform, you should normally contact that company first; we will assist it in responding.

To request deletion directly from GInIEm, email info@giniem.com and provide your name, the related company or telephone number, and the scope of your request. We will verify identity and delete or anonymize applicable data, except information we must retain for legal, security, or legal-defense purposes.

12. Children

Our business services are not intentionally directed to children. If you believe we received a child’s data without valid authorization, contact us so we can review and delete it where appropriate.

13. Policy changes

We may update this policy to reflect legal, technical, or service changes. We will publish the current version on this page and identify its update date.

14. Contact

For privacy questions or personal-data requests, contact: info@giniem.com