Privacy Policy
Last Updated:
1. Introduction
PINNACLE SOLUTIONS SERVICES LTD (RC 1883217) ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services, including WhatsApp Business automation and AI voice agent solutions.
2. Information We Collect
2.1 Business Information
- Company name and registration details
- Business contact information (email, phone, address)
- Authorized representative information
- Business verification documents
2.2 WhatsApp Communication Data
When providing WhatsApp Business automation services, we process:
- Customer phone numbers
- Message content and conversation history
- Media files (images, documents) shared via WhatsApp
- Interaction timestamps and patterns
- Customer preferences and opt-in/opt-out status
2.3 Voice Communication Data
When providing AI voice agent services, we process:
- Phone numbers (caller and recipient)
- Call recordings and transcripts
- Call duration and timing
- Voice interaction data
3. How We Use Your Information
We use collected information solely for:
- Providing WhatsApp and voice automation services
- Processing customer inquiries and support requests
- Sending transactional notifications and updates
- Improving service quality and performance
- Training AI models for better accuracy (anonymized data only)
- Complying with legal obligations
- Preventing fraud and abuse
4. WhatsApp Business API Compliance
4.1 End-to-End Encryption
All WhatsApp messages are protected by WhatsApp's end-to-end encryption. We do not have access to message content except as necessary to provide our automation services.
4.2 Opt-In Requirement
We only send WhatsApp messages to users who have explicitly opted-in to receive communications from our clients. Users can opt-out at any time by:
- Replying "STOP" to any automated message
- Contacting our support team directly
- Using the opt-out mechanism provided in message templates
4.3 WhatsApp Commerce Policy
We strictly adhere to WhatsApp's Commerce Policy and Business Policy, including:
- No spam or unsolicited messages
- Transparent business identity
- Respect for user privacy
- Compliance with local regulations
- Prohibition of misleading information
5. Nigeria Data Protection Regulation (NDPR) Compliance
5.1 Legal Basis for Processing
We process personal data based on:
- Consent from data subjects
- Performance of contract with our clients
- Compliance with legal obligations
- Legitimate business interests
5.2 Data Subject Rights
Under NDPR, individuals have the right to:
- Access their personal data
- Correct inaccurate data
- Request data deletion (right to be forgotten)
- Object to data processing
- Data portability
- Withdraw consent at any time
5.3 Data Localization
Customer data is stored on secure servers in compliance with NDPR requirements. We ensure appropriate safeguards for any cross-border data transfers.
6. Data Sharing and Disclosure
6.1 Third-Party Service Providers
We may share data with:
- WhatsApp Business API providers (Meta Platforms, Inc.)
- AI voice platform providers
- Cloud hosting and infrastructure providers
- Analytics and performance monitoring services
All third parties are bound by strict confidentiality and data protection agreements.
6.2 Business Clients
Customer conversation data is shared with our clients (the businesses using our automation services) as they are the data controllers for their customer interactions.
6.3 Legal Requirements
We may disclose information when required by:
- Nigerian law or court order
- Government or regulatory authorities
- Law enforcement agencies
- Protection of our legal rights and safety
7. Data Security
We implement appropriate technical and organizational measures to protect personal data:
- Encryption of data in transit and at rest
- Access controls and multi-factor authentication
- Regular security audits and penetration testing
- Employee training on data protection
- Incident response and breach notification procedures
- Secure data centers with physical security
8. Data Retention
We retain personal data only as long as necessary:
- WhatsApp conversation data: Up to 90 days unless longer retention is required for legal compliance
- Voice call recordings: Up to 30 days for quality assurance purposes
- Business information: Duration of business relationship plus 7 years for legal and tax compliance
- Anonymized analytics data: Retained indefinitely for service improvement
9. International Data Transfers
Some of our service providers (WhatsApp, AI platforms) may process data outside Nigeria. We ensure appropriate safeguards are in place through:
- Standard contractual clauses
- Data processing agreements
- Adequate protection mechanisms as required by NDPR
10. Children's Privacy
Our services are not directed to children under 18 years of age. We do not knowingly collect personal information from children. If we become aware of such collection, we will delete the information immediately and terminate the relevant account.
11. Your Rights and Choices
You have the right to:
- Request access to your data by emailing: [email protected]
- Request data correction or deletion
- Opt-out of marketing communications
- Object to automated decision-making
- Lodge a complaint with Nigeria Data Protection Bureau (NDPB)
- Receive your data in a structured, commonly used format
12. Contact Information
Data Protection Officer
PINNACLE SOLUTIONS SERVICES LTD
RC 1883217
Email: [email protected]
Phone: +234 912 783 1318
Business Hours: Monday - Friday, 9:00 AM - 6:00 PM WAT
For general inquiries:
Email: [email protected]
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by:
- Posting the updated policy on our website with a new "Last Updated" date
- Sending email notification to registered clients
- Displaying a prominent notice on our website
Your continued use of our services after such modifications constitutes your acknowledgment and acceptance of the modified Privacy Policy.
14. Governing Law
This Privacy Policy is governed by the laws of the Federal Republic of Nigeria, including:
- Nigeria Data Protection Regulation (NDPR) 2019
- Companies and Allied Matters Act (CAMA) 2020
- Other applicable Nigerian data protection and privacy laws
Acknowledgment
By using our services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms and conditions.