Privacy policy

Last updated: [TODO: publication date]

FlashReplai is an AI assistant that replies to customers on WhatsApp on behalf of local businesses. This policy explains what personal data we handle, why, who helps us handle it, and the rights you have. We wrote it with Egypt's Personal Data Protection Law (Law No. 151 of 2020) in mind.

The policy covers two different groups of people, and our role is different for each:

Who we are

FlashReplai is run by [TODO: full legal name], an independent developer, at [TODO: contact address]. You can reach us about anything in this policy at hello@flashreplai.ai.

Part 1: Website visitors and demo requests

Browsing the website

The website has no analytics, advertising or tracking cookies. It is served through our website hosting and security provider, which, like any web host, processes technical data such as your IP address, browser type and the pages you request, to deliver the site and protect it from attacks. Our provider doesn't publish a fixed retention period for this data; it says it keeps personal data for a period consistent with its business purposes.

The demo request form

When you request a demo, we ask for your name, business name, type of business, country and WhatsApp number, and optionally your email. You must tick a box agreeing to be contacted.

Why we use this data

Only to contact you about your demo and to send you a quote if you ask for one. The legal basis is your consent, which you give when you tick the box and can withdraw at any time by emailing us. We don't sell your data, use it for advertising, or add you to a mailing list.

Our clients' accounts

If your business becomes a client, we also keep the details of the staff who use the dashboard and the staff bot (name, email, messaging app account) and billing records, to run your account and send service emails. [TODO: retention period for client account and billing records]

Part 2: Customers of businesses that use FlashReplai

If you messaged a business on WhatsApp and an AI assistant replied, that business uses FlashReplai. The business is responsible for your data, and its own privacy policy applies too. This part explains what happens on our side.

What we process

What we use it for

We don't use your data for our own purposes, we don't sell it, we don't use it for advertising, and we don't use it to train AI models. Our AI model provider doesn't use this data to train its models. [TODO: turn on the AI search provider's training opt-out, then state that it doesn't train on it either]

The assistant is an AI

The assistant introduces itself as an AI assistant and never pretends to be a person. You can ask for a staff member at any time, and the conversation will be passed to the business's team.

Opting out

Businesses must have your permission before messaging you first on WhatsApp. If you no longer want messages from a business, tell it in the chat or contact it directly, and it must stop. You can also block the business in WhatsApp.

How long we keep it

By default, we keep conversations for 90 days, then delete them. [TODO: confirm recorded requests follow the same 90 days] When a business stops using FlashReplai, we delete its customers' data within 30 days. Backups are kept on a rolling 30-day cycle, so deleted data leaves our backups within a month.

Sensitive data

FlashReplai doesn't currently serve healthcare businesses. Please don't send health, financial or other sensitive information through the assistant, such as medical details, card numbers or passwords.

Who receives data

We use other companies to run the website and the service. Each receives only what it needs for its task, under its own terms and data protection commitments. They fall into these categories:

Transfers outside Egypt

Personal data is transferred and processed outside Egypt: in the United States (AI model provider and email delivery), Germany (our servers) and the Netherlands (backups). [TODO: add the regions for AI search, website hosting, messaging platforms, our inbox and spreadsheet export] We only transfer it to providers that commit to protecting it, and as Law 151 of 2020 allows. [TODO: confirm licensing or registration status with Egypt's Personal Data Protection Center for cross-border transfers]

Client businesses can ask us for the list of the specific service providers we use at hello@flashreplai.ai. We tell our clients [TODO: notice period] before we add a new provider in any of these categories.

How we protect data

Data is encrypted in transit, access is limited to the people who need it, and each business can see only its own customers' conversations. If a breach affects your data, we will notify the business, the Personal Data Protection Center and affected people as the law requires. [TODO: confirm encryption at rest]

Your rights

Under Law 151 of 2020 you have the right to:

Website visitors and demo requests: email hello@flashreplai.ai and we'll reply within 30 days.

Customers of a business: contact the business first, since it controls your data. If you contact us instead, we'll pass your request to the business and help it respond.

How to delete your data

To delete your demo request, or your messages with a business that uses FlashReplai, email hello@flashreplai.ai with the WhatsApp number you used and, for a business, its name. We'll confirm once the data is deleted, apart from anything the law requires us or the business to keep.

Children

The website and the demo form are for businesses and are not meant for anyone under 18.

Changes to this policy

If we change this policy, we'll update the date at the top. If the change is significant, we'll tell our clients before it takes effect.

Contact

Questions or requests about your data: hello@flashreplai.ai. See also our terms of service.