Privacy Policy

This Privacy Policy explains how Satani Ventures LLP ("Satani Ventures," "we," "our," or "us") processes personal information in connection with our WhatsApp app. Through that app, a business connects its own WhatsApp account and uses it to send and receive messages, including automated replies the business has configured.

This Policy covers that app. It does not cover our consultancy website or our consulting engagements. Those are described in our website privacy policy.

Satani Ventures LLP is a limited liability partnership registered in India. Our office is at PL-86, Angel Villa, Kholvad, Surat, Gujarat 394190.

For account information a business gives us directly, we are the Data Fiduciary under India's Digital Personal Data Protection Act, 2023 ("DPDP Act"). Where the GDPR, the UK GDPR, or a similar law applies to that business contact, we are the controller.

For the content of WhatsApp messages, and for personal information about the people who send them, the business whose account is connected is the Data Fiduciary or controller. We process that information on that business's instructions, to provide the messaging that business configured. We are the processor, or the equivalent, for that information. This Policy explains our processing. It does not replace the privacy notice that business gives to the people who message it.

This Policy applies to two groups.

• A business that connects a WhatsApp account to the app, and the people at that business who administer the connection.
• A person who messages that WhatsApp account, or who receives a message sent through the app. That person does not create an account with us.

4.1 From the business

• The business's name, and the name and email address of the person who sets up or administers the connection.
• The WhatsApp Business Account and the phone number the business connects.
• The credentials the platform issues so the app can act on that account.
• The settings the business chooses for how replies are produced and sent.

4.2 From WhatsApp

When a message is sent or received on a connected account, the app receives what the WhatsApp Business Platform provides for that message. That includes:

• The content of the message, including text, images, audio, video, and files.
• The sender's phone number and, where the platform includes it, the sender's display name.
• Delivery and read status, and the identifiers the platform assigns to the message and the account.

We keep each business's WhatsApp information separate from every other business's. We do not use one business's messages for another business.

We use this information for these purposes:

• To connect the business's WhatsApp account and keep that connection working.
• To send and receive the messages the business configures, including template messages.
• To produce an automated reply when the business has turned that on, as Section 6 describes.
• To protect the app, to diagnose faults, and to respond to a security report.
• To meet a legal duty, and to establish or defend a legal claim.

We do not sell this information. We do not use it for our own advertising. We do not use WhatsApp message content to train a model of our own.

Where the business has configured an automated reply, we send the message content needed to produce that reply to a model provider outside Satani Ventures. The provider processes that content in order to return the reply. The message leaves our systems for that purpose.

The provider is not yet fixed. Before any customer's WhatsApp messages are sent to a model provider, this Policy will name the provider and will state whether that provider may use the content to train or improve its own models. Until this Policy does both of those things, we do not send customer message content to a model provider.

• Meta Platforms, which operates WhatsApp. Sending and receiving a message requires that the platform process it under its own terms.
• A model provider, on the terms in Section 6, and only once this Policy names that provider.
• A hosting provider that runs the app for us, once we engage one. The host is not yet fixed. Before customer message content is stored on a provider's systems, this Policy will name that host.
• A professional adviser, an authority, or a court, where the law requires the disclosure.

Satani Ventures is established in India. A model provider or a host may process information in another country. Where information leaves India, the United Kingdom, or the European Economic Area, we put in place the safeguards the applicable law requires, including contractual terms with the recipient where those are required.

We do not keep a conversation history for a business to read back. Message content is used to produce and deliver the reply the business has configured. We do not retain it as a transcript.

We keep the business's account, the WhatsApp connection, the credentials for that connection, and the reply settings while that account is open. When the account closes, we delete the platform data we hold for that business, including any message content still in our systems.

Where the law requires us to keep a record, we keep that record for the period the law requires and we do not use it for any other purpose. A business, or a person who sent a message, can ask us to delete sooner. Section 9 explains how.

You can ask us to delete personal information the app holds about you. This is available to a business that connected an account, to a person who administers that account, and to a person who sent or received a message through it. You do not need an account with us to ask.

Email satanialish@gmail.com and include:

• That you are asking for deletion.
• Whether you are the business, someone who administers the business's account, or a person who messaged that account.
• The business name, the WhatsApp phone number, or both, so we can find the information.

We will delete the platform data we hold for that request. We will confirm by email. We may keep a record where the law requires it, and we will tell you if we do. We may need to confirm that you are the person the information is about, or that the business has asked you to write, before we delete it.

If you messaged a business, you can also ask that business to delete the conversation. The business decides what it keeps in its own systems. This request deletes what Satani Ventures holds.

We use access controls, encrypted transport, and limited access by the people who need the information for their work. Each business's WhatsApp data is kept separate. No method of transmission or storage is perfectly secure, and we do not promise that it is.

If you believe information has been compromised, or you want to report a vulnerability in the app, email satanialish@gmail.com. We will acknowledge a security report and work on it.

Depending on the law that applies to you, you may have the right to:

• Ask whether we hold personal information about you, and to receive a copy.
• Ask us to correct information that is inaccurate or incomplete.
• Ask us to erase it, as Section 9 describes, subject to records we are required to keep.
• Withdraw consent, where consent was the basis of the processing.
• Object to processing based on legitimate interests.
• Raise a grievance with us and, if it is not resolved, with the Data Protection Board of India.
• Nominate another person to exercise your rights if you die or become unable to do so, where the DPDP Act provides that right.
• Complain to a supervisory authority in your country, where one exists.

Where we process message content on a business's instructions, we will also pass a request about that content to the business, and we will help the business respond as the arrangement with that business requires. To make a request, use Section 9 or Section 14.

The app is for businesses. Under the DPDP Act, a child is a person under 18. We do not knowingly collect personal information from children. If you believe we have done so, contact us and we will delete it.

We may update this Policy. The version on this page, with its "Last updated" date, is the current one. If a change is material and the law requires notice, we will give it. Naming a model provider, and stating whether that provider may train on message content, is a change we will make on this page before any customer's messages are sent to that provider.

For questions about this Policy, to exercise a right, or to report a security problem, contact:

• Data Fiduciary: Satani Ventures LLP
• Grievance contact: Alish Satani
• Email: satanialish@gmail.com
• Postal address: PL-86, Angel Villa, Kholvad, Surat, Gujarat 394190

We will acknowledge a grievance and work to resolve it within the time the applicable law requires.