Privacy Policy

1. Information We Collect

1.1 Personal Information

We may collect the following types of personal information:

• Contact Information: Name, email address, phone number, business address
• Business Information: Company name, job title, industry, business needs
• Communication Data: Messages sent through WhatsApp, chat logs, support tickets
• Account Information: Username, password, preferences, settings
• Technical Information: IP address, device information, browser type, operating system
• Usage Data: How you interact with our services, features used, time spent

1.2 WhatsApp Business API Data

When you interact with our WhatsApp services, we collect:

• WhatsApp phone numbers
• Message content and conversation history
• Delivery and read receipts
• Media files shared (images, documents, voice messages)
• User preferences and interaction patterns

1.3 Automatically Collected Information

We automatically collect certain information through cookies and similar technologies:

• Website usage analytics
• Performance metrics
• Error logs and debugging information
• Security and fraud prevention data

2. How We Use Your Information

We use your personal information for the following purposes:

• Service Provision: To deliver our premium AI-powered solutions and WhatsApp services
• Customer Support: To respond to inquiries, provide technical support, and resolve issues
• Communication: To send important updates, notifications, and service announcements
• Personalization: To customize your experience and improve our AI responses
• Analytics: To analyze usage patterns and improve our services
• Security: To protect against fraud, unauthorized access, and security threats
• Compliance: To comply with legal obligations and regulatory requirements
• Marketing: To send promotional materials (only with your consent)

3. Legal Basis for Processing

Under the Botswana Data Protection Act and GDPR, we process your personal data based on:

• Consent: When you explicitly agree to data processing
• Contract: To fulfill our contractual obligations to you
• Legitimate Interest: For business operations, security, and service improvement
• Legal Obligation: To comply with applicable laws and regulations
• Vital Interest: To protect your essential interests or those of others

4. Information Sharing and Disclosure

We may share your information in the following circumstances:

4.1 Service Providers

We work with trusted third-party service providers who assist us in:

• Cloud hosting and data storage
• WhatsApp Business API services (Meta/Facebook)
• Analytics and performance monitoring
• Customer support tools
• Payment processing

4.2 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity.

4.3 Legal Requirements

We may disclose your information when required by law, court order, or to:

• Comply with legal processes
• Protect our rights and property
• Ensure user safety and security
• Investigate potential violations

4.4 Consent

We may share your information with your explicit consent for specific purposes.

5. Data Storage and Security

5.1 Data Location

Your data is stored in secure data centers located in:

• Botswana (primary)
• South Africa (backup and disaster recovery)
• European Union (for GDPR compliance)

5.2 Security Measures

We implement industry-standard security measures including:

• End-to-end encryption for sensitive data
• Multi-factor authentication
• Regular security audits and penetration testing
• Access controls and employee training
• Secure backup and disaster recovery procedures
• Compliance with ISO 27001 standards

5.3 Data Retention

We retain your personal data for as long as necessary to:

• Provide our services
• Comply with legal obligations
• Resolve disputes
• Enforce our agreements

Specific retention periods:

• Account Information: Until account deletion + 30 days
• WhatsApp Messages: 2 years or as required by law
• Transaction Records: 7 years for accounting purposes
• Support Tickets: 3 years for quality assurance

6. Your Rights

Under the Botswana Data Protection Act and GDPR, you have the following rights:

6.1 Access Rights

• Request copies of your personal data
• Obtain information about how we process your data
• Receive data in a structured, machine-readable format

6.2 Correction Rights

• Correct inaccurate personal data
• Complete incomplete personal data
• Update your preferences and settings

6.3 Deletion Rights

• Request deletion of your personal data
• Withdraw consent for data processing
• Object to processing based on legitimate interests

6.4 Restriction Rights

• Limit how we process your data
• Object to direct marketing
• Restrict automated decision-making

6.5 Portability Rights

• Transfer your data to another service provider
• Receive your data in a portable format

To exercise your rights, contact us at privacy@aluvium.co.bw

7. WhatsApp Business API Specific Terms

7.1 Meta/Facebook Integration

Our WhatsApp services use the Meta WhatsApp Business API. By using our WhatsApp services, you acknowledge that:

• Meta's terms and privacy policy also apply
• Message data is processed through Meta's infrastructure
• We comply with Meta's Business API requirements
• End-to-end encryption applies to personal messages

7.2 Business Communications

When you communicate with businesses through our WhatsApp services:

• Business messages may not be end-to-end encrypted
• We may store conversation history for service improvement
• AI analysis may be applied to improve responses
• You can opt out of business communications at any time

7.3 Opt-Out Mechanisms

You can opt out of WhatsApp communications by:

• Sending "STOP" or "UNSUBSCRIBE" via WhatsApp
• Contacting our support team
• Using the opt-out link in business messages
• Blocking our WhatsApp Business number

8. Cookies and Tracking Technologies

8.1 Types of Cookies

We use the following types of cookies:

• Essential Cookies: Required for website functionality
• Performance Cookies: Help us understand website usage
• Functional Cookies: Remember your preferences
• Marketing Cookies: Used for targeted advertising (with consent)

8.2 Cookie Management

You can control cookies through:

• Browser settings
• Our cookie consent banner
• Third-party opt-out tools
• Privacy settings in your account

8.3 Third-Party Analytics

We use Google Analytics, Meta Pixel, and other analytics tools. These services may collect:

• Website usage statistics
• User demographics (anonymized)
• Conversion tracking data
• Performance metrics

9. International Data Transfers

We may transfer your data internationally for:

• Cloud storage and backup services
• Third-party service providers
• Business operations and support

We ensure adequate protection through:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by data protection authorities
• Binding Corporate Rules (BCRs)
• Certification schemes

10. Children's Privacy

Our services are not directed to children under 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete such information.

If you believe we have collected information from a child, please contact us immediately at admin@aluvium.co.bw

11. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by:

• Posting the updated policy on our website
• Sending email notifications to registered users
• Displaying prominent notices on our platform
• WhatsApp notifications for service-related changes

Your continued use of our services after any changes constitutes acceptance of the updated Privacy Policy.

12. Contact Information

12.1 Data Protection Officer

For privacy-related inquiries, contact our Data Protection Officer:

12.2 Supervisory Authority

You have the right to lodge a complaint with the relevant supervisory authority:

12.3 General Contact

13. Effective Date and Governing Law

This Privacy Policy is effective as of January 9, 2025, and is governed by the laws of Botswana. Any disputes arising from this Privacy Policy will be subject to the exclusive jurisdiction of the courts of Botswana.

For users in the European Union, this Privacy Policy also complies with the General Data Protection Regulation (GDPR).