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:
- Visitors to flashreplai.ai and people who request a demo. Here, FlashReplai decides how your data is used, so we are the controller. See Part 1.
- Customers who message a business that uses FlashReplai on WhatsApp. Here, the business decides how your data is used and is the controller. FlashReplai is the processor: we handle the data only on the business's instructions, to run the service for it. See Part 2.
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.
- Our website stores nothing. When you press send, the form is checked and immediately passed on as an email to hello@flashreplai.ai (sent through our email delivery service) and as a message to our team on a team messaging app. It is not saved in any database on the website.
- The email arrives in our inbox, which is hosted by an email provider, and the message stays in our team chat. We keep them for 12 months, then delete them.
- To block spam, the form uses a security check from our website hosting provider, which checks your browser and IP address to tell people apart from bots.
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
- Your WhatsApp number and the profile name you set in WhatsApp.
- The messages you exchange with the business, including the assistant's replies and any replies from the business's staff.
- Voice notes, images and files you send are not analyzed or used by the assistant. [TODO: describe how the app handles them today: downloaded, stored or discarded]
- Requests recorded from the conversation, such as an order, booking, complaint or outage report, with the details you gave.
What we use it for
- To reply to you on the business's behalf, using only the information the business has given us.
- To record your requests for the business and pass the conversation to its staff when needed.
- To keep the service secure and working, and to fix problems.
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:
- AI model providers read customers' messages and the business's information, to write the assistant's replies. Data is stored in the United States. [TODO: replies may be generated outside the US unless US-only processing is set; state which] Our provider deletes it within 30 days, or keeps it up to 2 years if it's flagged for breaking the provider's usage policy, and doesn't use it to train its models.
- AI search providers process the business's information, such as prices, hours and policies, to find the relevant answer to each question. [TODO: confirm whether customer messages are also sent to the AI search provider; if so, say so here] [TODO: region: the provider's docs don't state it] [TODO: retention: once the training opt-out is on, the provider deletes data right after processing it]
- Cloud hosting, storage and backup providers store conversations, recorded requests and accounts on our servers in Germany, where the WhatsApp Web sessions described below also run. Backups of our database are stored in the Netherlands (Amsterdam) on a rolling 30-day cycle. [TODO: confirm the backups are encrypted]
- Email delivery services send demo requests to our inbox and service emails, such as sign-in and notification emails, to clients' staff. Our email delivery service stores data in the United States and keeps email and log data for 30 days. Our inbox, where demo requests and support emails arrive, is hosted by an email provider. [TODO: where our inbox provider stores mail]
- Website hosting and security services serve the website and app, run the demo form, and check visitors' IP address, browser and connection details to block bots and attacks. Our provider doesn't publish a fixed retention period for this data. [TODO: region: the provider runs a global network]
- Messaging platforms send and receive messages:
- WhatsApp carries every message between customers and the business, and also processes messages under its own privacy policy. Some business numbers are connected through a WhatsApp Web session that runs on our servers in Germany. This is not an official WhatsApp connection: messages pass through that session to our servers. Numbers connected through WhatsApp's official Business Platform send and receive messages through a messaging provider. [TODO: region for WhatsApp and for the official-platform messaging provider]
- A team messaging app delivers new demo requests to our team, and lets a business's staff receive alerts and reply to conversations passed to them, so those messages pass through it. [TODO: region]
- Spreadsheet export, only when a business chooses to send recorded requests to its own online spreadsheet. The records are then copied into the business's spreadsheet account. [TODO: region]
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:
- know whether we hold your data, and get a copy of it;
- correct data that is wrong or incomplete;
- have your data deleted;
- withdraw your consent, or object to or restrict how your data is used;
- be told if a breach affects your data;
- complain to Egypt's Personal Data Protection Center.
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.