Privacy Policy
Last updated: September 22, 2025
1. Introduction
Recall ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our multi-channel business communication platform, including our integration with WhatsApp Business API and other messaging services.
By using our services, you agree to the collection and use of information in accordance with this policy. We comply with applicable data protection laws, including GDPR, CCPA, and Meta's Business Terms and Commercial Terms.
2. Information We Collect
2.1 Personal Information
- Contact information (name, email address, phone number)
- Business information (company name, job title, business address)
- Account credentials and authentication data
- Payment and billing information
2.2 Communication Data
- Messages sent and received through our platform
- Customer contact information and communication history
- Media files (images, documents, voice messages) shared through messaging channels
- Communication metadata (timestamps, delivery status, read receipts)
2.3 Technical Information
- Device information (IP address, browser type, operating system)
- Usage data (features used, session duration, error logs)
- Cookies and similar tracking technologies
- API usage data and performance metrics
3. How We Use Your Information
We use the collected information for the following purposes:
3.1 Service Provision
- Provide and maintain our communication platform
- Process and deliver messages through integrated channels
- Enable multi-account management and switching
- Provide customer support and technical assistance
3.2 Business Operations
- Process payments and manage subscriptions
- Generate analytics and usage reports
- Improve our services and develop new features
- Ensure platform security and prevent fraud
3.3 Legal Compliance
- Comply with applicable laws and regulations
- Respond to legal requests and court orders
- Protect our rights and interests
- Enforce our terms of service
4. WhatsApp Business API Integration
Our platform integrates with Meta's WhatsApp Business API. When using this integration:
- We comply with Meta's Business Terms and Commercial Terms
- Message content is processed according to WhatsApp's policies
- We do not store WhatsApp message content beyond what is necessary for service delivery
- All communications are encrypted in transit and at rest
- We maintain audit logs as required by Meta's policies
- We only send messages to users who have opted in to receive communications
- We provide clear opt-out mechanisms in all WhatsApp messages
- We respect user preferences and honor unsubscribe requests immediately
- We do not share WhatsApp contact information with third parties without consent
- We maintain data processing records as required by Meta's policies
4.1 WhatsApp Data Processing
When processing data through WhatsApp Business API, we act as a data processor on behalf of our business customers. We:
- Process data only as instructed by our business customers
- Implement appropriate technical and organizational measures to protect data
- Assist our customers in responding to data subject requests
- Notify customers of any data breaches involving WhatsApp data
- Maintain records of data processing activities
5. Data Sharing and Disclosure
We may share your information in the following circumstances:
5.1 Service Providers
We may share information with third-party service providers who assist us in operating our platform, including cloud hosting providers, payment processors, and analytics services.
5.2 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction.
5.3 Legal Requirements
We may disclose information when required by law, court order, or to protect our rights and the safety of our users.
6. Data Security
We implement appropriate technical and organizational measures to protect your information:
- End-to-end encryption for all communications
- Secure data storage with industry-standard encryption
- Regular security audits and vulnerability assessments
- Access controls and authentication mechanisms
- Employee training on data protection practices
7. Data Retention
We retain your information for as long as necessary to provide our services and comply with legal obligations:
- Account information: Until account deletion or 3 years of inactivity
- Communication data: As required for service delivery and legal compliance
- Analytics data: Aggregated and anonymized data may be retained longer
- Legal requirements: Some data may be retained longer to comply with applicable laws
8. Consent and User Choices
We respect your choices regarding how we collect, use, and share your information:
8.1 WhatsApp Communications
- We only send WhatsApp messages to users who have explicitly opted in
- You can opt out of WhatsApp communications at any time by replying "STOP"
- We honor opt-out requests immediately and remove you from our messaging lists
- You can update your communication preferences through our platform
8.2 Marketing Communications
- You can opt out of marketing emails by clicking the unsubscribe link
- We provide clear opt-in mechanisms for all marketing communications
- You can manage your communication preferences in your account settings
9. Your Rights
Depending on your jurisdiction, you may have the following rights:
- Access: Request access to your personal information
- Correction: Request correction of inaccurate information
- Deletion: Request deletion of your personal information
- Portability: Request a copy of your data in a portable format
- Restriction: Request restriction of processing
- Objection: Object to certain types of processing
To exercise these rights, please contact us using the information provided in the "Contact Us" section below.
10. International Data Transfers
Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place for such transfers, including:
- Standard contractual clauses approved by relevant authorities
- Adequacy decisions by relevant data protection authorities
- Other appropriate safeguards as required by applicable law
11. Children's Privacy
Our services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically for any changes.
13. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us:
Email: privacy@minervamatrix.com
Address: [Your Business Address]
Phone: [Your Contact Number]
Data Protection Officer: dpo@minervamatrix.com
14. Regulatory Compliance
This Privacy Policy is designed to comply with:
- General Data Protection Regulation (GDPR)
- California Consumer Privacy Act (CCPA)
- Meta's Business Terms and Commercial Terms
- WhatsApp Business API Terms of Service
- Other applicable data protection laws
This Privacy Policy is effective as of September 22, 2025 and will remain in effect except with respect to any changes in its provisions in the future.