Privacy Policy – WhatsApp Business Platform

1. Who We Are

Triton Middle East LLC (referred to as "Triton," "we," "us," or "our") is the data controller responsible for processing your personal data as described in this policy.

2. Scope of This Policy

This privacy policy applies when you:

• Send or receive messages with us through WhatsApp Business Platform
• Interact with our WhatsApp Cloud API (operated directly through Meta Business Manager)
• Click on WhatsApp links, buttons, QR codes, or ads (Meta ads) that connect you to our business
• Communicate with our AI-powered sales and support assistants
• Receive approved WhatsApp Business template messages from us
• Have your conversations processed through our automation workflows (N8N)
• Are recorded in our CRM system (Bitrix24) as part of customer interactions

Note: This policy specifically covers WhatsApp communications. Our website and other services may have separate privacy notices. WhatsApp's own service is operated by WhatsApp LLC/WhatsApp Ireland Limited under their Privacy Policy.

3. Data We Collect

3.1 Information You Provide

• Identity Data: Name, business name, job title
• Contact Data: WhatsApp phone number, country, preferred language (English/Arabic)
• Message Content: Text messages, voice notes, images, videos, documents, and any other files you share
• Location Data: If you choose to share your location via WhatsApp

3.2 Information We Generate

• Conversation Context: Lead qualification data, sales inquiries, support tickets, customer preferences
• CRM Records: Lead scores, interaction history, notes added by our team
• AI Processing Data: Intent classification, sentiment analysis, conversation summaries

3.3 Technical Information

• WhatsApp Metadata: Your WhatsApp ID, message timestamps, delivery/read receipts
• Channel Source: How you reached us (QR code, website button, Meta ad, direct message)
• Session Data: Conversation thread IDs, automation workflow triggers

4. How You Consent (Opt-In)

You provide consent to receive WhatsApp messages from us when you:

• Initiate Contact: Send us the first message on WhatsApp (this is your primary consent)
• Website Forms: Submit a form on our website with your phone number and check the WhatsApp communication box
• QR Codes: Scan our WhatsApp QR code at events or from marketing materials
• Meta Ads: Click "Message on WhatsApp" from our Facebook/Instagram advertisements
• Verbal Consent: Provide your number to our staff with explicit agreement to be contacted via WhatsApp
• Template Response: Respond positively to our initial WhatsApp Business template message

5. How and Why We Use Your Data

6. WhatsApp-Specific Information

6.1 End-to-End Encryption

WhatsApp provides end-to-end encryption for messages in transit. However, as a business using WhatsApp Cloud API:

• Messages are decrypted when they reach our business systems
• Our authorized staff and AI systems can access message content to serve you
• Conversations are stored in our secure databases for service continuity

6.2 24-Hour Messaging Window

• Customer Service Window: When you message us, we can reply with free-form messages for 24 hours
• Template Messages: Outside this window, we can only send pre-approved template messages
• Types of Templates: Service updates, appointment reminders, marketing offers (with your consent)

6.3 Opt-Out Options

You can stop receiving messages from us at any time by:

• Replying STOP to any of our messages
• Using the unsubscribe option in message menus
• Blocking our number in WhatsApp settings
• Emailing us at info@triton.me
• Calling us at +971 551640274

7. AI Assistants and Automation

7.1 AI-Powered Conversations

We use AI technology to enhance your experience:

• AI Assistants: Powered by OpenAI API, Google Gemini API, Groq, and other providers
• Identification: AI assistants introduce themselves as "assistant" at the beginning of conversations
• Human Agents: Our human team members introduce themselves by name
• Escalation: You can request a human agent at any time

7.2 Automation Workflow (N8N)

• N8N automation platform orchestrates our conversation flows
• Has access to partial conversation content needed for routing and triggers
• Implements memory for contextual AI responses
• Enables human-in-the-loop interventions when needed

7.3 AI Data Usage

• We do NOT directly train AI models on your conversation data
• We DO use conversations for quality assurance and service improvement
• AI providers process your messages to generate responses (not for their training)*
• Conversation summaries may be stored in CRM for service continuity

*Depends on our service agreements with API providers, it may prevent training on customer data.

8. Data Sharing and Recipients

We share your data only as necessary for the purposes described above:

8.1 Service Providers

• Meta/WhatsApp: WhatsApp Cloud API operation and message delivery
• AI Providers: OpenAI, Google (Gemini), Groq - for generating AI responses
• Automation: N8N - for workflow automation and conversation routing
• CRM Systems: Bitrix24 - for customer relationship management
• Database Providers: MongoDB, Supabase, Firebase - for data storage
• Telecommunications: Etisalat - for phone number services

8.2 Other Recipients

• Professional Advisors: Lawyers, accountants, auditors (under confidentiality)
• Authorities: When required by UAE law, valid court orders, or legitimate requests from competent authorities (e.g., UAE regulatory bodies)
• Business Transfers: In case of merger, acquisition, or asset sale

8.3 Corporate Affiliates and Sister Companies

To provide you with the most relevant and efficient service, we may share your information, including your contact details and conversation history, with our subsidiary or group companies. This sharing occurs only when necessary for purposes such as:

• Routing your sales inquiry or support request to the specialist team in the relevant company
• Providing integrated services that involve more than one entity within our group
• Fulfilling orders that require coordination between different group entities
• Internal administrative and reporting purposes

We ensure that all companies within our corporate group adhere to data protection standards consistent with this privacy policy and are bound by appropriate confidentiality and security obligations.

9. International Data Transfers

Your data may be processed in multiple locations:

• Primary Storage: UAE and United States data centers
• Service Providers: May be located in EU, UK, US, or other countries
• Safeguards: We ensure appropriate protections through:
  • UAE PDPL compliance measures
  • Standard Contractual Clauses (for EU/UK transfers)
  • Data processing agreements with all providers
  • Technical security measures (encryption, access controls)

10. Data Retention

10.1 Retention Periods

10.2 Deletion Requests

• You can request deletion of your data at any time
• We will process deletion requests within 30 days
• Some data may be retained if required by law or for legitimate business purposes

11. Security Measures

We implement comprehensive security measures to protect your data:

11.1 Technical Measures

• End-to-end encryption for WhatsApp messages in transit
• TLS/SSL encryption for all data transfers
• Encrypted databases with access logging
• Regular security updates and patches
• Web Application Firewall (WAF) protection

11.2 Organizational Measures

• Role-based access controls (RBAC)
• Employee confidentiality agreements
• Regular security training for staff
• Vendor security assessments
• Incident response procedures

11.3 Backup and Recovery

• Daily automated backups
• Geographically distributed backup storage
• Regular recovery testing
• Business continuity planning

12. Your Privacy Rights

Depending on your location and applicable laws, you have the following rights:

12.1 Universal Rights

• Access: Request a copy of your personal data
• Correction: Update or correct inaccurate data
• Deletion: Request removal of your data (subject to legal requirements)
• Portability: Receive your data in a structured format
• Objection: Object to certain processing activities
• Restriction: Limit how we use your data
• Withdraw Consent: Opt-out of marketing at any time

12.2 How to Exercise Your Rights

Contact us through any of these channels:

• Email: info@triton.me
• WhatsApp: +971 551640274
• Post: Block 1, Plot 27, Sector 4, Umm Al Thuoob, New Industrial Area, Emirate of Umm Al Quwain, UAE, P.O. Box 3350

Response Time: We will respond to your request within 30 days

Verification: We may need to verify your identity before processing requests

13. Children's Privacy

Our WhatsApp Business services are intended for adults (18 years and older). We do not knowingly:

• Collect personal data from children under 18
• Market our services to minors
• Process children's data without parental consent

If we become aware that we have collected data from a child, we will promptly delete it. Parents/guardians can contact us if they believe we have inadvertently collected their child's information.

14. Contact Information

15. Changes to This Policy

We may update this privacy policy to reflect:

• Changes in our data processing practices
• New features or services
• Legal or regulatory requirements
• Feedback from users or authorities

Notification: We will notify you of material changes through:

• WhatsApp message (for active users)
• Notice on our website
• Updated "Last modified" date at the top of this policy

We encourage you to review this policy periodically. Continued use of our WhatsApp services after changes indicates acceptance of the updated policy.