PRIVACY POLICY

OVERVIEW

This Privacy Policy explains how Irakli Beselidze LLC ("Calen.ai", "we", "us", "our") collects, uses, shares and deletes personal data. It applies to the Calen.ai website (https://calen.ai), the OmniInbox app and the CalenAI platform (together, the "Service").

The Service is a customer communication platform for businesses. Businesses use it to connect their WhatsApp Business, Facebook Messenger and Instagram accounts, answer customer messages with automated replies and human agents in one inbox, book appointments, and receive leads from Meta Lead Ads.

This policy covers three groups of people:

• Website visitors: people who browse calen.ai or contact us through it.
• Customers: businesses that use the Service, and the people who work for them.
• End users: people who message, call or send a form to a business that uses the Service.

You can ask us to delete your personal data at any time. See Section 9 or go to https://calen.ai/data-deletion.

SECTION 1 - OUR ROLE

For website visitors and Customers, Calen.ai decides how and why personal data is used. We are the data controller.

For end users, the business you are communicating with decides how and why your data is used. That business is the data controller, and Calen.ai processes your data on its behalf as its processor. The privacy policy of that business also applies to you. You can send a privacy request to that business or directly to us.

SECTION 2 - PERSONAL DATA WE COLLECT

From website visitors we collect:

• Contact form details: full name, position, company email, phone number and the information you give us about your business.
• Web chat: the messages you send through the chat window on our website and any contact details you share in it.
• Data deletion requests: your name, email, the account or profile you ask us to delete and any details you add.
• Technical data: IP address, browser and device type, pages visited and the date and time of each visit.

From Customers we collect:

• Account data: name, work email, phone number, company name, role and login details.
• Connected Meta accounts: when a Customer connects an account through Meta's login or Embedded Signup, we receive the name and ID of the person who connects it, the names and IDs of the WhatsApp Business Accounts, phone numbers, Facebook Pages, Instagram professional accounts and Lead Ads forms they choose to connect, and the access tokens that let us send and receive messages for them.
• Billing data: subscription plan, invoices and payment status. Payments are handled by third-party payment providers. Calen.ai does not process or store payment card information.
• Support and usage data: your messages to our support team and records of how the Service is used, such as logins and settings changes.

About end users we receive the following data from the channels a Customer has connected:

• WhatsApp: phone number, WhatsApp profile name, the messages and attachments you exchange with the business, and message times and delivery status.
• Facebook Messenger and Instagram: your user ID for that Page or account, profile name, username and profile picture where Meta makes them available, the messages and attachments you exchange with the business, and message times.
• Meta Lead Ads: the answers you submit in a business's lead form, such as name, email and phone number, and the form the lead came from.
• Appointments: the name, contact details, date, time and service for an appointment you book with a business.
• Calls: where a Customer uses Calen.ai to automate or analyse phone calls, the call recordings, transcripts and call details that the Customer provides.

We do not ask end users for full payment card numbers, financial account numbers or national identification numbers, and our Customers are not allowed to ask for them in chat. Please do not send this kind of information in a conversation.

SECTION 3 - HOW WE USE PERSONAL DATA

We use website visitor data to answer your enquiries, arrange calls and demonstrations, process data deletion requests, and run, measure and secure our website.

We use Customer data to create and manage accounts, connect the channels a Customer chooses, provide the Service, bill for it, give support, send notices about the account and the Service, prevent abuse and fraud, and meet our legal obligations. We send marketing messages only where you have agreed to them, and you can opt out at any time.

We use end user data only to provide the Service to the Customer you are communicating with, on that Customer's instructions. This means we:

• receive your messages and show them to the business in its inbox;
• send you the replies written by the business's human agents;
• create and send automated replies on the business's behalf;
• book and manage appointments;
• deliver leads from Meta Lead Ads to the business;
• keep the Service secure and fix technical problems.

Some replies are produced automatically by software, including AI models, on behalf of the business. Businesses that use automated replies must give you a clear way to reach a human agent or another support channel.

SECTION 4 - DATA WE RECEIVE FROM META PRODUCTS

Data we receive from WhatsApp, Facebook Messenger, Instagram, Meta Lead Ads and Meta login is called "Platform Data". We process Platform Data only to provide the Service to the Customer who connected the account, on that Customer's instructions.

• We do not sell, license or purchase Platform Data.
• We do not use Platform Data for advertising, profiling or any purpose unrelated to the Service.
• We do not share Platform Data except with the Customer it belongs to, with the sub-processors needed to run the Service, or where the law requires it.
• We delete Platform Data as described in Sections 7 and 9.

We handle Platform Data in line with the Meta Platform Terms (https://developers.facebook.com/terms/). Messages sent through WhatsApp, Messenger and Instagram also pass through Meta's systems. Meta's use of your data is described in the Meta Privacy Policy (https://www.facebook.com/privacy/policy/) and the WhatsApp Privacy Policy (https://www.whatsapp.com/legal/privacy-policy).

SECTION 5 - LEGAL BASES

Where data protection law requires a legal basis, we rely on the following:

• Contract: to provide the Service to Customers and to answer requests you send us.
• Legitimate interests: to run, secure and improve our website and the Service, and to prevent abuse.
• Consent: for marketing messages and, where the law requires it, for analytics cookies. You can withdraw consent at any time.
• Legal obligation: to keep records and answer lawful requests from authorities.

For end user data, the Customer is responsible for having a legal basis, including any opt-in needed before it sends you messages.

SECTION 6 - WHO WE SHARE PERSONAL DATA WITH

We do not sell personal data. We share it only with:

• The Customer: end user data is available to the business you contacted and to the people it gives access to.
• Meta Platforms: to send and receive messages through the WhatsApp Cloud API, Messenger and Instagram.
• Sub-processors: providers that host and run the Service for us, such as cloud hosting, messaging, email and AI model providers. They may use the data only to provide their service to us. Our sub-processors are listed in our Data Processing Agreement, which we send to Customers on request. To ask for it or for the current list, email support@calen.ai.
• Tools a Customer connects: for example a calendar, a CRM or a payment provider that the Customer chooses to use with the Service.
• Analytics providers: Google Analytics, for website usage data only, as described in Section 10.
• Authorities and legal advisers: where the law requires it, or to protect the rights, property or safety of Calen.ai, our users or the public.
• A successor: if our business is merged, sold or reorganised, under the protections of this policy.

SECTION 7 - HOW LONG WE KEEP PERSONAL DATA

• Platform Data and other end user data: we keep it while the Customer's account stays connected. When a Customer disconnects an account or its subscription ends, we delete the related data within 30 days, unless the law requires us to keep it longer.
• Customer account data: we keep it while the account is active and afterwards for as long as we need it for legal, tax and accounting purposes.
• Website enquiries and chat messages: we keep them for as long as we need them to answer you and manage our relationship with you.

You can ask us to delete your data sooner. See Section 9.

SECTION 8 - SECURITY

We protect personal data with industry-standard security measures. Data sent between your browser, our servers and connected messaging platforms (such as WhatsApp, Messenger and Instagram) is encrypted in transit using HTTPS. Access to personal data is limited to the people and providers who need it to run the Service. No system is completely secure. If you think your data or account has been compromised, contact us at support@calen.ai.

SECTION 9 - YOUR RIGHTS AND HOW TO DELETE YOUR DATA

Depending on where you live, you may have the right to:

• ask for a copy of the personal data we hold about you;
• ask us to correct it;
• ask us to delete it;
• ask us to restrict or stop using it;
• receive it in a portable format;
• withdraw consent you have given;
• complain to your local data protection authority.

To delete your data, use either of these:

• Fill in the form on our Data Deletion page: https://calen.ai/data-deletion
• Email support@calen.ai with the subject "Data deletion request".

Anyone whose data we hold can make this request, including people who contacted a business through WhatsApp, Messenger or Instagram. We give you a reference code when we receive your request. We may contact you to confirm your identity. We delete your personal data within 30 days and confirm by email. If the law requires us to keep some of it, we tell you what we keep and why.

If your request is about your conversations with a particular business, we also work with that business to complete it, because that business is the controller of the data.

You can also stop the sharing of data at its source. Customers can disconnect their WhatsApp, Facebook and Instagram accounts at any time in the Service or in their Meta Business settings. If you connected Calen.ai to your Facebook account, you can remove it in your Facebook settings under Apps and websites.

To use any other right, email support@calen.ai.

SECTION 10 - COOKIES AND SIMILAR TECHNOLOGIES

Our website uses Google Analytics to measure how visitors use the site, such as the pages viewed and the type of device and browser. Google Analytics sets cookies only if you choose "Accept" in the cookie banner. If you choose "Reject" or make no choice, no analytics cookies are set and Google receives only limited measurement signals that do not use cookies.

We store your choice in your browser. You can change it at any time with the "Cookie settings" link at the bottom of every page. You can also use Google's opt-out tool (https://tools.google.com/dlpage/gaoptout).

The chat window on our website runs on our own platform. When you open the chat, it sets a cookie named cc_vid, which holds a visitor ID for one year so that your conversation continues between pages and visits. This cookie is needed for the chat to work, so it does not depend on your choice in the cookie banner.

Our website also loads fonts and images from third-party servers, such as Google. Those providers receive your IP address when your browser requests the files.

We do not use cookies for advertising.

SECTION 11 - INTERNATIONAL TRANSFERS

We and our service providers process personal data in several countries, which may be outside the country where you live. Where the law requires it, we use legal safeguards for these transfers.

SECTION 12 - CHILDREN

The Service is intended for businesses and for people who are at least 18 years old. It is not directed to children, and we do not knowingly collect personal data from children. If you believe a child has given us personal data, contact us at support@calen.ai and we will delete it.

SECTION 13 - CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. We post the new version on this page and change the "Last updated" date at the top. If a change is significant, we also tell Customers by email or in the Service.

SECTION 14 - CONTACT

Questions about this Privacy Policy or about your personal data should be sent to Irakli Beselidze LLC at support@calen.ai.

Our Terms of Service are available at https://calen.ai/terms-of-service.