Privacy Policy & Data Protection Governance Your data, your rights, clearly explained.

Version: 2.2.0  |  Effective Date: October 2026  |  Status: Global Privacy Governance & Data Protection Policy

1. Roles of the Parties (Data Controller vs. Data Processor)

To ensure strict regulatory clarity under Article 4 and Article 28 of the GDPR:

• Account & Registration Data: Upinno acts as the Data Controller regarding customer contact details, login credentials, billing transaction histories, and security audit logs.
• Customer Messaging & End-Consumer Data: With respect to direct messages, social comments, end-buyer shipping addresses, and transaction slips processed on behalf of the customer, the Customer acts as the Data Controller, and Upinno operates strictly as the Data Processor carrying out documented automation instructions.

---

2. Information We Collect and Process

• Identity & Authentication Data: Name, business email, authorized phone numbers, and encrypted third-party social media access tokens (Instagram, Meta Page IDs, WhatsApp Business, Telegram IDs).
• Operational Interaction Data: Inbound message bodies and comments routed through Upinno pipelines for real-time automated chatbot responses.
• Payment & Order Data: Machine-vision character extraction from customer-uploaded bank transfer slips strictly to streamline merchant order reconciliation.
• Technical Telemetry: Anonymized IP addresses, browser agents, access timestamps, and webhook response payloads used for DDoS mitigation, intrusion detection, and performance telemetry.

---

3. Explicit Purposes of Processing

We process personal data strictly for legitimate operational purposes:

• Providing core platform access, user authentication, and secure workspace provisioning.
• Executing automated chat workflows, in-chat checkouts, and omnichannel message routing.
• Subscription billing, transaction auditing, and fraud prevention.
• Delivering customer technical support and responding to administrative inquiries.
• Transmitting critical service alerts, technical updates, and security notifications.
• Maintaining network security, load balancing, and anti-spam heuristic monitoring.

---

4. Artificial Intelligence Policy (Zero Public Model Training)

1. No Foundation Model Training: Upinno unconditionally warrants that private customer communications, direct messages, brand product catalogs, and confidential business workflows are never used to train, fine-tune, or reinforce public foundation models.

2. In-Context Inference Only: Prompts and context vectors are processed strictly in transient memory (RAM) during live inference. Contextual buffers are purged from runtime instances upon delivery of the response.

---

5. Data Security Architecture & Personnel Access

Pursuant to Article 32 of the GDPR, Upinno deploys defense-in-depth security measures:

• Encryption at Rest: All social media OAuth access tokens and private credentials are encrypted at rest using AES-256-GCM. Encryption keys are maintained in isolated environment vaults decoupled from the primary database.
• Encryption in Transit: All data transmissions between clients, Upinno cloud clusters, and external social webhooks are protected with TLS 1.3 / HTTPS.
• Multi-Tenant Isolation: Customer data is logically segregated using unique workspace tenant keys (workspace_id), preventing cross-tenant access.
• Least Privilege Personnel Access: Server and database access is strictly restricted to vetted operational engineers on a need-to-know basis and audited with comprehensive access logs.

---

6. Data Retention, Automated Pruning, and Right to Erasure

1. Automated 90-Day Message Pruning: To comply with data minimization mandates (Article 5(1)(c) GDPR), direct messages, bot transaction logs, and customer comments older than ninety (90) days are automatically and irrevocably deleted from operational databases.

2. Right to Erasure (Article 17 GDPR): Customers may revoke social channel tokens or request full account termination at any time via the dashboard. Upon account closure, all associated workspace data is purged within seventy-two (72) hours.

3. Encrypted disaster recovery snapshots are automatically overwritten and purged on a rolling 30-day lifecycle.

---

7. Managing and Revoking Third-Party App Permissions

Customer remains bound by the terms and policies of connected third-party platforms. In addition to disconnecting channels within Upinno, you can unilaterally revoke access permissions directly at the provider level:

• Facebook & Instagram: Meta Business Integrations & Connected Apps Settings
• Telegram: Telegram App > Settings > Privacy and Security > Active Sessions.
• Google Services: Google Account Connected Third-Party Permissions

---

8. CCPA / CPRA Notice: "We Do Not Sell Personal Information"

Upinno does not sell, rent, or lease personal information or user-generated chat data to data brokers, ad networks, or external third parties for monetary or other valuable consideration.

---

9. Contact the Data Protection Officer (DPO)

For inquiries regarding privacy, exercising data subject rights, or security disclosures, contact our Data Protection Office:

• Email: [email protected] / [email protected]
• Support Desk: Available via the in-app support ticketing terminal.

---

10. Controlling Language

This Privacy Policy is executed in the English language. Any translation is provided solely for reference. In the event of any conflict, discrepancy, or ambiguity between the English version and any translated version, the English version shall govern, control, and prevail.