Privacy Policy
Última atualização: [TODO: publication date]
Este documento é publicado apenas em inglês. O texto em inglês é a versão que faz fé; ainda não existe tradução disponível.
This policy explains what personal data Baliza handles, why, and what rights you have. It covers our website, our web and mobile applications, and the Baliza chat widget that our customers embed on their own websites.
1. Who we are
Baliza is a customer conversation platform operated by [TODO: registered legal entity name], [TODO: registered address], [TODO: company registration number]. You can reach us about privacy at [TODO: privacy contact address, e.g. privacy@balizachat.com].
[TODO: state whether a Data Protection Officer has been appointed and give their contact details, or state that one is not required.]
2. Our two different roles
This is the most important thing to understand about how Baliza handles data, because it determines who you should contact about your information.
We are the data controller for the accounts of our own customers — the businesses that sign up for Baliza. That means we decide how we handle their sign-up details, organisation records and usage of the service.
We are a data processor for the conversations those businesses have with their own customers. When you chat with a business that uses Baliza, that business decides what happens to your messages; we only store and transmit them on that business's instructions. Their privacy policy governs that data, not this one.
3. If you chatted with a business that uses Baliza
You are talking to that business, not to us. We host the conversation on their behalf. To ask what they hold about you, to request a copy, or to ask for deletion, contact that business directly — they are the controller and they can act on your request. If you contact us instead, we will refer you to them, and we may need to pass your request on so it can be handled.
What we store on their behalf when you use the chat widget is described under 'Data we process for our customers' below.
4. Data we hold as controller (our customers' accounts)
When someone creates or is invited to a Baliza account, we handle:
- Identity and sign-in details: name, email address, and a hashed password. Passwords are never stored in a readable form.
- Email verification and password reset tokens.
- Organisation and team records: organisation name, team membership, and the role that determines what each person can access.
- Invitations sent to colleagues, including the invited email address.
- Sessions and devices, so you can stay signed in and we can end a session when you sign out.
- API keys created for integrations.
- Usage records, including counts of AI requests and their token cost, so the service can be operated and billed.
- Support correspondence you send us.
We use this to provide the service, keep accounts secure, respond to support requests, and meet our legal obligations. We do not sell personal data, and we do not use our customers' conversation content to train AI models.
5. Data we process for our customers
Our customers decide what enters the service. Depending on which channels they enable, this can include:
- Contact records: name, email address, phone number, and identifiers from the channel a person used.
- Conversation content: the messages exchanged, along with timing, assignment and routing information.
- Files and media sent in a conversation, including photos, documents and voice notes.
- Channel identifiers, such as an email address for email conversations or a Telegram account identifier.
- Web chat session data, including IP address and browser user agent, used to keep a conversation attached to the right visitor and to protect the service against abuse.
- Appointment bookings, and — where the customer enables it — records of missed appointments used to apply their booking rules.
- Knowledge base articles our customers write, and the search indexes generated from them.
- Device tokens for push notifications to our customers' own staff.
Optional website engagement tracking in the chat widget is switched off unless a customer turns it on. When enabled, those events are automatically deleted after the retention period that customer chooses — either 30 or 90 days.
6. Messaging channels: WhatsApp, Instagram and Messenger
Our customers can connect their own WhatsApp Business number, Instagram professional account or Facebook Page to Baliza, through the WhatsApp Business Platform, the Instagram API and the Messenger Platform operated by Meta. A customer connects an account by signing in with Meta and granting Baliza permission to read and send that account's messages; they can withdraw that permission at any time.
For a connected account, we receive and store, on the customer's behalf:
- Messages people send to the account, and messages the account sends — including replies written in Meta's own apps — with their timestamps.
- The sender's identifiers from that channel: a WhatsApp phone number or business-scoped user ID, a WhatsApp profile name, or an Instagram-scoped user ID.
- Delivery and read status of messages, and, when an operator opens a conversation, a read or seen notice sent back to the person who wrote.
- For the connected business account itself: its account ID, username or phone number, and the permissions granted.
The access token Meta issues for a connected account is stored encrypted and used only to send and receive that account's messages and keep the connection working. It is never shown in our interfaces or logs. Message notifications from Meta are verified, and their raw content is kept encrypted for up to 14 days so a delivery that failed can be processed again; after that it is deleted.
We use this data only to provide the messaging service to the customer who connected the account. We do not use it for advertising, we do not sell it, and we do not share it with anyone other than the service providers listed below, the customer's chosen AI provider when they enable AI replies, and Meta itself to deliver messages.
To disconnect, a customer can remove Baliza from the connected account's settings — on Instagram under Settings, Apps and websites; for WhatsApp and Facebook Pages in Meta Business settings — or ask us to remove the channel. How to have data deleted is explained on our Data Deletion page (/data-deletion).
7. AI features and where conversation content goes
Baliza does not ship with a built-in AI provider. Each customer connects their own AI service by supplying its address and credentials.
This means that when a customer enables AI replies, the message content and any relevant knowledge base material needed to answer are sent to the AI service that customer chose, under that customer's own agreement with that provider. We do not select that provider, and we are not party to that relationship. Customers should check their provider's terms — in particular whether it retains or trains on submitted content — and reflect it in their own privacy notice.
9. Service providers we use
We rely on the following categories of provider to run Baliza. Business customers can request the current sub-processor list with named entities and locations.
- Cloud hosting and database services for running the application and storing data.
- Object storage for files and media sent in conversations.
- An email delivery provider, used both for our own transactional email and for customers who enable the email channel.
- Messaging platforms for the channels a customer enables: Telegram, and Meta Platforms for WhatsApp, Instagram and Messenger.
- Push notification services operated by Apple, Google and our mobile build provider, to deliver alerts to our customers' staff devices.
- A background job service that runs message processing and scheduled clean-up tasks.
- Error monitoring and product analytics services, used to diagnose faults and understand how the application is used.
- Where a customer enables AI features, the AI provider that customer configures.
[TODO: replace this category list with the named legal entities, their processing locations, and a link to the maintained sub-processor page before publication. Business customers will ask for this, and the DPA must reference it.]
10. How long we keep data
- Account data: for as long as the account is active, and afterwards only as long as needed for legal, accounting or dispute-resolution purposes.
- Conversation content and contacts: kept until the customer deletes it or closes their account, since they decide the retention that applies to their own records.
- Web chat engagement events, when enabled: automatically deleted after 30 or 90 days, depending on the customer's setting.
- Unfinished file uploads: automatically deleted once they expire.
- Raw message notifications from WhatsApp, Instagram and Messenger: kept encrypted for up to 14 days, then deleted. The messages themselves follow the conversation retention above.
- Error and diagnostic logs: [TODO: state the retention period configured with your monitoring providers].
[TODO: confirm the deletion timeline offered after account closure — for example 'deleted within 30 days of account closure' — and make sure the implementation matches the promise.]
11. Why we are allowed to use this data
Where the GDPR applies, we rely on: performance of a contract, to provide the service to our customers; our legitimate interests, in keeping the service secure, preventing abuse and improving it; consent, where it is required, such as for optional tracking; and compliance with legal obligations, such as accounting duties.
[TODO: have a lawyer confirm this mapping against your final feature set and marketing practices.]
12. Where data is stored and transferred
The Baliza application and its database are hosted in the European Union, and conversation content and contact records are stored there.
Some data still leaves that region in specific, limited circumstances: when a customer enables a messaging channel, messages travel through that platform's own infrastructure; push notifications to our customers' staff devices are delivered through Apple and Google; and where a customer configures an AI provider outside the EU, the content sent for a reply goes there under that customer's own arrangement.
[TODO: confirm the hosting provider and EU region, and state the safeguard relied on for the transfers named above — normally Standard Contractual Clauses. List which named sub-processors process outside the EEA.]
13. How we protect data
- Passwords are stored using a modern, deliberately slow hashing algorithm, never in readable form.
- Traffic between your browser or device and Baliza is encrypted in transit.
- Access inside an organisation is limited by role, and inboxes can be restricted so staff only see the conversations that belong to their team.
- Data belonging to different customer organisations is kept separated within the service.
- The mobile app can be locked behind your device's biometric or passcode protection.
- Websites can cryptographically verify a signed-in visitor's identity before the widget trusts it, so one visitor cannot impersonate another.
No service can promise perfect security, but we treat a breach affecting personal data seriously and will notify affected customers and, where required, the relevant supervisory authority.
14. Your rights
Depending on where you live, you may have the right to access the personal data held about you, correct it, delete it, restrict or object to its use, receive a portable copy, and withdraw consent you previously gave. You also have the right to complain to your data protection authority.
For data we hold as controller — a Baliza account — contact us and we will respond within the period the law allows. For a conversation you had with a business using Baliza, contact that business, as explained above.
[TODO: name the lead supervisory authority for your establishment and how to reach it.]
15. Children
Baliza is a tool for businesses and is not directed at children. We do not knowingly create accounts for children. If a customer uses Baliza in a context where children may be in contact with them, it is that customer's responsibility to handle that lawfully in their own privacy notice.
16. Changes to this policy
We will update this policy when our handling of data changes, and will revise the date at the top. If a change materially affects our customers, we will notify them directly rather than relying on this page alone.
17. Contact us
Questions about this policy or about your data can be sent to [TODO: privacy contact address] or by post to [TODO: registered address].