PRIVACY POLICY

Last updated: October 29, 2025

1. Data Controller

Tenkiu SAS, NIT 123456789-0, headquartered in Ibagué, Colombia. Contact: contact@tenkiu.app

2. Data We Collect

3. Purposes

4. Legal Basis

User consent and execution of the service contract. Compliance with legal obligations (billing, fraud prevention).

5. Data Retention

Account data: while the account is active. Message history: up to 6 months. Voice messages and transcriptions: up to 6 months. Accounting records: 5 years. After retention periods, data may be anonymized or deleted.

6. Data Sharing & Third-Party Processors

Your data may be shared with the following third parties under strict confidentiality and data processing agreements:

6.1 AI Processing of WhatsApp Messages

When you interact with a business via WhatsApp on Tenkiu, your messages may be processed by artificial intelligence systems (OpenAI GPT-4 and Anthropic Claude) to:

Important Guarantees:

  • ✅ Your conversation data is used exclusively to provide Tenkiu services
  • ✅ AI providers are contractually prohibited from training their models on your data
  • ✅ Your data is not shared with other businesses or used for marketing
  • ✅ Message content is retained for a maximum of 6 months
  • ✅ Business owners can disable AI processing through their dashboard at any time

6.2 WhatsApp Business Solution Compliance

Tenkiu complies with the WhatsApp Business Solution Terms (effective January 15, 2026), including:

7. Meta / WhatsApp Business API Processing

To send and receive messages via WhatsApp, your data (phone number, messages, and interactions) is processed by Meta Platforms, Inc. according to their Privacy Policy: https://www.facebook.com/about/privacy.

Our Privacy Policy URL is configured in the "Privacy Policy URL" field of the Meta Developer Portal and the WhatsApp Business Account settings.

By using the Embedded Signup flow, you authorize Meta to verify and activate your WhatsApp Business Account.

8. Data Subject Rights

You have the following rights regarding your personal data:

All data subject requests can be submitted via contact@tenkiu.app. We will respond within 30 days.

Note: Business owners control whether AI is enabled for their WhatsApp conversations. If you have concerns about AI processing of your messages, please contact the business directly.

9. Voice Message Processing

If you send voice messages via WhatsApp, they may be transcribed using AI technology (OpenAI Whisper or Google Cloud Speech-to-Text) to enable text-based processing and search.

What we do:

Your rights:

10. Security Measures

TLS encryption, OTP hashing, role-based access control, encrypted backups.

11. Cookies

We use first- and third-party cookies for analytics (Google Analytics) and functionality. You can manage preferences in your browser settings.

12. Policy Changes

Updates will be published on this page and significant changes notified 30 days in advance.

13. DPO Contact

Data Protection Officer: contact@tenkiu.app

14. Shopkeeper-Specific Privacy Terms

If you operate a business on Tenkiu, additional data processing terms apply:

14.1 Shopkeeper as Data Controller

Critical: As a business owner using Tenkiu's WhatsApp integration, you are the Data Controller for all customer data collected through your WhatsApp conversations, including:

  • Customer phone numbers and names
  • Message content and conversation history
  • Voice messages and transcriptions
  • Order information (items, delivery addresses, payment details)
  • Customer location data (if shared)

Tenkiu acts as your Data Processor, processing this data on your behalf according to your instructions and our agreement.

14.2 Your Data Protection Obligations

As a Data Controller, you must:

14.3 Data We Collect About Shopkeepers

In addition to basic account data, we collect from shopkeepers:

14.4 How We Use Shopkeeper Data

14.5 Data Sharing for Shopkeeper Services

Your business data may be shared with:

14.6 Customer Data Access & Deletion

14.7 AI Processing on Your Behalf

When AI systems process your customer messages:

14.8 Your Responsibilities

As a business owner on Tenkiu, you are responsible for:

  • ✅ Informing your customers that their messages may be processed by AI
  • ✅ Obtaining necessary consents for data processing under applicable laws
  • ✅ Responding to customer data subject requests (access, deletion, correction)
  • ✅ Maintaining your own privacy policy that covers your use of Tenkiu services
  • ✅ Protecting customer data you access through Tenkiu's platform
  • ✅ Complying with all applicable data protection laws in your jurisdiction
  • ✅ Notifying customers and authorities in case of data breaches