Draft: pending legal review
This document is a draft template and is not yet in effect. Items in [brackets] will be completed after legal review.
Privacy Policy
Last updated: [LAST_UPDATED_DATE]
This Privacy Policy explains how [LEGAL_ENTITY_NAME] (“Onedly”, “we”, “us”) collects, uses, shares and protects personal data when you visit onedly.com and when businesses use our software products.
We build business software for companies in the Middle East and North Africa. Some of our products help businesses communicate with their own customers through the WhatsApp Business Platform. This policy covers both our website and those products.
1. Who we are
[LEGAL_ENTITY_NAME], registered at [REGISTERED_ADDRESS], commercial registration number [COMMERCIAL_REGISTRATION_NO]. You can contact us about privacy at [PRIVACY_CONTACT_EMAIL].
2. Our role
- Controller: we decide how personal data is used for our website, our enquiries and the accounts of the businesses that use our products (our “Customers”).
- Processor (service provider): when a Customer uses our products to message its own customers (“End Users”), we process End User data on the Customer’s behalf and only on its documented instructions. The Customer is responsible for giving End Users its own privacy notice and for obtaining any opt-in or consent that WhatsApp Business policies and applicable law require.
3. Personal data we collect
Depending on how you interact with us, we collect:
| Category | Examples | Source |
|---|---|---|
| Enquiries | Name, email address, company, the content of your message | You, through our contact form or by email |
| Customer account data | Names, business email addresses, phone numbers, job titles, company details, billing details | Our Customers and their staff |
| End User messaging data | WhatsApp phone number, WhatsApp profile name, message content, message metadata (time sent, delivered and read status), and order details a Customer shares with us (for example order number, items, amount and delivery address) | Our Customers and their End Users, through the WhatsApp Business Platform |
| Technical data | IP address, browser type, pages requested and time of the request, recorded in server logs | Automatically, when you use our website or products |
Our website does not use advertising or analytics cookies and does not load third-party tracking scripts. [CONFIRM before publication: no cookies are used on the website.]
4. How we use personal data
- To reply to your enquiries and manage our business relationships.
- To provide, operate, maintain and support our products for Customers, including sending and receiving WhatsApp messages on their behalf.
- To provide AI-assisted features that Customers enable, for example drafting replies or classifying incoming messages. End Users are told when they are interacting with an automated system and can reach a person at the Customer.
- To keep our services secure, prevent abuse and fix problems.
- To meet legal, tax and accounting obligations.
We do not sell personal data. [CONFIRM: We do not use Customer or End User message content to train AI models.]
5. Legal bases
Where the law requires a legal basis, including Egypt’s Personal Data Protection Law No. 151 of 2020 and, where it applies, the EU or UK GDPR, we rely on: performance of a contract with you or your organisation; our legitimate interests in running and securing our business; compliance with legal obligations; and your consent where we ask for it. [Legal review: confirm the applicable laws and bases for each market.]
6. Service providers we use
We share personal data only with service providers that help us run our website and products, under contracts that limit their use of the data:
| Provider | Purpose |
|---|---|
| [HOSTING_PROVIDER] | Website and application hosting |
| [EMAIL_PROVIDER] | Delivering emails, including contact form messages |
| Meta (WhatsApp Business Platform) | Sending and receiving WhatsApp messages for Customers. Messages pass through Meta’s infrastructure and are also subject to WhatsApp’s business terms and Meta’s privacy policy. |
| [AI_MODEL_PROVIDER] | Language-model processing for AI-assisted features |
| [PAYMENT_PROCESSOR] | Processing Customer subscription payments |
We may also disclose personal data when required by law, to protect our rights or the safety of others, or as part of a merger or acquisition, subject to this policy. [Publish and maintain a current list of sub-processors at: SUBPROCESSOR_LIST_URL.]
7. International transfers
Some of our service providers process data outside the country where it was collected. When this happens we use safeguards required by applicable law, such as contractual protections or regulator permits. [Legal review: confirm transfer mechanisms and any licence required under Egyptian law.]
8. How long we keep data
- Enquiries: [CONTACT_RETENTION_PERIOD] after our last exchange.
- Customer account data: for the duration of the contract and [ACCOUNT_RETENTION_PERIOD] after it ends, unless the law requires longer.
- End User messaging data: as instructed by the Customer, and deleted or returned within [CUSTOMER_DATA_DELETION_PERIOD] after the Customer’s contract ends.
- Server logs: [LOG_RETENTION_PERIOD].
9. Security
We use technical and organisational measures appropriate to the risk, such as encryption in transit, access controls and least-privilege access for staff. No system is completely secure, and we will notify affected Customers and authorities of a personal data breach where the law requires.
10. Your rights
Subject to applicable law, you can ask to access, correct or delete your personal data, object to or restrict its processing, receive a copy in a portable format, and withdraw consent at any time. You can also complain to your data protection authority; in Egypt this is the Personal Data Protection Center.
If you are an End User who received messages from a business that uses our products, please contact that business first, as it controls your data. We will help it respond. You can also block the business in WhatsApp at any time.
11. Requesting data deletion
To ask us to delete your personal data, email [PRIVACY_CONTACT_EMAIL] with the subject “Data deletion request” and include the email address or WhatsApp number the request relates to. We will confirm your identity, act on the request within [RESPONSE_PERIOD], and tell you the outcome. Where we process the data for a Customer, we will forward your request to that Customer.
12. Children
Our website and products are intended for businesses and are not directed at children under 18. We do not knowingly collect their personal data.
13. Changes to this policy
We will update this policy when our products or practices change and will show the date of the latest version at the top. We will notify Customers of material changes in advance.
14. Contact
[LEGAL_ENTITY_NAME], [REGISTERED_ADDRESS]. Privacy questions and requests: [PRIVACY_CONTACT_EMAIL]. General enquiries: [COMPANY_CONTACT_EMAIL].