Privacy Policy

Effective [EFFECTIVE DATE PENDING] • Version 2026-10-29.1

1 Who we are and when this policy applies

Voitella, company number [COMPANY NUMBER PENDING], of [ADDRESS PENDING], operates Relay. Contact [PRIVACY CONTACT PENDING] about this policy or your information. Where legally required, our data protection officer or representative is [NAME AND CONTACT OR DELETE IF NOT REQUIRED].

This policy covers our website, dashboard, gateway, APIs, and support. We determine the purposes of account administration, service security, support, and our own legal records. For messages and related personal data that a business customer instructs us to handle, that customer generally determines the purposes and we process on its behalf under a DPA. The customer’s notices explain its purposes and lawful basis. Roles depend on the actual activity and applicable law, not solely the label in a contract.

If your information appears in a customer’s conversation, contact that business first about its use of it. You may also contact us; we will identify the appropriate route without unnecessarily revealing other people’s information. WhatsApp, Meta, authentication providers, and customer-selected destinations have separate notices for activities they independently control. This policy is not a request for blanket consent.

2 Information we receive

Account and support information includes the account identifier supplied through sign-in, available profile or contact information, organization details you provide, service settings, and correspondence. We do not need your WhatsApp password to pair an account. The sign-in provider handles its own authentication credentials under its terms.

Connected-account information includes the linked number or account identifiers, device and session identifiers, connection status, and cryptographic session credentials needed to maintain access. A pairing QR code or code authorizes a device session and must be treated as a secret. Session credentials can allow continuing access until revoked.

Customer Content may include message text and captions; attachments or references; sender, recipient, chat, and group identifiers; names and participant details; timestamps and delivery events; synchronized history; drafts and queued content; monitoring keywords and matches; and webhook payloads. Availability depends on platform synchronization. Connecting an account can expose more conversations than intended; monitoring filters do not necessarily limit gateway synchronization or storage.

Technical information may include request and event identifiers, access times, IP addresses and device or browser details recorded by hosting or authentication infrastructure, errors, security activity, and delivery attempts. We receive configured webhook destinations and permitted media URLs. Support messages and attachments may contain additional personal information you choose to send. Do not send live keys or unnecessary sensitive content.

Sources include you, your organization’s authorized users, its linked WhatsApp sessions, its API requests and integrations, sign-in services, and our hosting and operational systems. We do not buy contact lists for the gateway. The current gateway does not collect payment card data; if paid checkout is introduced, we will identify the payment provider and update this notice before that processing begins.

3 Purposes and legal grounds

We use account and technical information to operate and secure Relay, handle support, communicate service changes, investigate misuse, and maintain required business records. Where a legal basis is required, we use contract performance for an individual customer, legitimate interests for business contacts and service security after balancing affected rights, legal obligations, or consent where required. A corporate customer’s contract is not a universal legal basis for processing employees’ or message participants’ information.

We process Customer Content to establish and maintain the linked session, synchronize and display available conversations, retain requested history, operate rules, submit queued messages, deliver events, and provide instructed support. The business customer is responsible for the lawful basis and notices for those instructions. Where we independently investigate abuse or comply with law, we identify a separate lawful basis as required.

Relay does not use Customer Content to train general-purpose AI models, sell it, or use it for behavioral advertising. The current gateway’s keyword monitoring is rule-based, not an external AI analysis service. If an AI integration is later offered, its data flow, recipient, purpose, and contractual safeguards must be disclosed before activation. Hosting the dashboard within ChatGPT Sites does not mean this policy overrides the host’s separate processing terms.

4 Pairing group access and monitoring

Pairing authorizes Relay’s gateway to act as a linked endpoint for the account. The gateway can receive readable messages and group information available to that account. An account holder’s ability to view a group does not itself authorize exporting everyone’s information, covert workplace monitoring, or sending marketing to participants.

Customers must give notices, obtain necessary permissions, and configure access and destinations appropriately. Rule matches and forwarded events can contain original message text. A monitor restricted to selected chats does not currently guarantee that all other chats are excluded from history synchronization. Customers should use an account dedicated to the permitted business activity and avoid linking personal or mixed-use accounts.

WhatsApp’s transport protections do not prevent an authorized linked endpoint from reading content. We can decrypt stored gateway payloads using service-held keys. Do not interpret “encrypted” as a claim that Relay is technically unable to access your information or that every record is encrypted at the application layer.

5 Who receives information

We disclose information to authorized users within the relevant customer account and to recipients and destinations the customer instructs us to contact. Customer webhook, CRM, automation, media-hosting, and other external services may receive content and technical information needed for those instructions. Their copies and independent processing are governed by their arrangements with the customer and applicable law.

We use hosting, storage, authentication, and operational providers to run Relay. The deployment design uses ChatGPT Sites and its Cloudflare-based infrastructure for the dashboard and database, and Railway for the separate gateway once provisioned. The current contracting entities, processing locations, service roles, and transfer arrangements must be identified in https://relay-whatsapp-workspace.dreamartai.chatgpt.site/legal/subprocessors. Infrastructure operators may process data under their own terms for limited independent purposes as disclosed in their notices.

WhatsApp processes communications under the customer’s relationship with the relevant WhatsApp entity. Its role can vary by product and activity; it is not automatically a Relay subprocessor. Baileys is a software library, not by that fact a separate recipient of message content. We may disclose minimum necessary information to professional advisers under confidentiality duties, to authorities where legally required, and to protect legal rights or address credible threats as permitted by law. We review legal demands and give notice where lawful.

If our business is reorganized, financed, or transferred, necessary information may be disclosed under confidentiality and appropriate safeguards. Any successor must honor applicable obligations. We do not make customer conversations public as part of a public dashboard or public marketing page. Customers must still avoid exposing content or credentials in screenshots, shared links, or external integrations.

6 Security and access

We use authentication, tenant checks, credential controls, and encryption for selected gateway fields. The gateway design encrypts stored session credentials and message payloads, stores API key hashes rather than recoverable raw API keys, and signs webhook requests. Production transport must use HTTPS. Some workspace fields and routing metadata are not covered by that application-layer encryption.

Authorized access may be necessary for support, incident investigation, and legal duties. We restrict access to what is needed and require confidentiality. No method of storage or transmission is absolutely secure. This policy does not claim a completed security audit, SOC 2 or ISO certification, universal encryption at rest, or immunity from account compromise. Report a suspected incident to [SECURITY CONTACT PENDING].

7 Retention and deletion

We retain personal information only for the relevant service purpose, a lawful documented retention need, or our duties under applicable law. During the current pilot, the gateway does not automatically expire message history, events, or queued records. Those records can remain stored until manually removed following a verified instruction or account closure. A customer must choose an appropriate retention schedule before using production or sensitive data; a final retention schedule will be published at https://relay-whatsapp-workspace.dreamartai.chatgpt.site/legal/retention.

Disconnecting a session deletes its stored authentication state in the gateway but does not by itself erase messages, chats, queue records, monitoring events, dashboard records, or copies in external systems. Revoke linked-device access in WhatsApp as well if you suspect compromise. Removing a message from WhatsApp does not guarantee synchronized removal of Relay’s stored copy. Disappearing-message and view-once settings also do not currently ensure deletion of synchronized Relay records; do not use Relay to defeat a participant’s privacy expectations.

To request return or deletion, contact [PRIVACY CONTACT PENDING]. Subject to verification, applicable law, and the DPA, we will coordinate with the relevant customer and carry out an authorized deletion request without undue delay and within the applicable legal deadline. The DPA provides the contractual process at termination. We will explain a lawful exception rather than representing that all records have been erased.

The gateway currently has no configured application backup schedule. Hosting providers may hold infrastructure snapshots, logs, or other copies under their service arrangements; their actual retention and deletion periods must be confirmed in the completed retention schedule. Legal or security holds are limited to what is necessary, access-restricted, and reviewed. We cannot delete recipients’ devices, the customer’s own archives, or customer-selected services’ independent copies.

8 International processing

Information may be processed in the countries used by the operator, its authorized support personnel, and infrastructure providers. The countries and safeguards for this deployment are [COUNTRIES AND TRANSFER MECHANISMS TO CONFIRM]. We do not promise that selecting one hosting region confines all support access, telemetry, backups, or onward processing to that region.

Where legally required, we use a valid transfer mechanism, such as an applicable adequacy decision or properly completed standard contractual clauses, with additional assessments and safeguards where necessary. Contact [PRIVACY CONTACT PENDING] for relevant information or a copy of applicable safeguards subject to appropriate redactions. Use of the service is not blanket consent to international transfers. Restricted transfers must not begin before the required arrangements are completed.

9 Rights and requests

Depending on applicable law, you may have rights to information, access, correction, erasure, restriction, portability, objection, withdrawal of consent, and complaint to a competent data protection authority. Some rights have conditions and exceptions. Where processing relies on legitimate interests, you may object based on your circumstances; where direct marketing objection rights apply, we will honor them. Withdrawal does not invalidate lawful processing before withdrawal.

Send requests to [PRIVACY CONTACT PENDING]. We may request proportionate information to verify identity and authority, but will not require unnecessary sensitive documents. We respond within legally required periods and explain any permitted extension or refusal. You may use an authorized agent where the law allows. We do not retaliate for exercising protected privacy rights.

Where we act as a processor, we generally refer the request to the customer and assist it under the DPA. We may act directly where the law requires. Rights do not allow access to another person’s messages or bypassing account security. An individual’s lawful rights are not waived by the customer’s commercial agreement.

10 Cookies marketing and automated decisions

The dashboard, sign-in, and hosting infrastructure may use storage necessary for authentication, security, and preferences. We have not added advertising pixels or behavioral advertising tools to the gateway. Before introducing optional analytics or marketing tracking, we will describe it and obtain consent where required. Browser controls may affect login. Host-controlled technologies are described in the host’s notice.

A future Relay marketing program would require an appropriate legal basis and effective opt-out. Essential service and security notices may still be sent. Keyword rules trigger customer-configured events; Relay does not independently make decisions with legal or similarly significant effects about message participants.

Relay is directed to adult business users and is not designed for children. Customers should not intentionally submit children’s data or specially regulated information without a separate lawful arrangement and appropriate safeguards. If you believe information was provided without authority, contact us so we can investigate and take appropriate action.

11 Changes and contact

We will update this policy when processing changes and identify the effective date. For material changes, we will provide appropriate notice before the change takes effect where required. Posting a revision does not by itself supply consent, a lawful basis, or an international transfer mechanism. Contact [PRIVACY CONTACT PENDING] or [ADDRESS PENDING] with questions, requests, or complaints.