Privacy Notice
Last updated: 26th June 2023
This policy applies to all websites, chatbots, and products built and maintained by inChat Ltd including inchat.design, bots.inchat.design, the inChat platform, and Weekchat (including all versions of). When we say “Company”, “we”, “our”, or “us” in this document, we are referring to inChat Ltd..
This policy applies to our handling of information about site visitors, prospective customers, and customers and authorised users (in relation to their procurement of the services and management of their relationship with inChat Ltd). We refer collectively to these categories of individuals as "you" throughout this policy.
However, this policy does not cover information about a customer’s end users that inChat receives from a customer, or otherwise processes on a customer’s behalf, in connection with the services provided by inChat to the customer pursuant to an applicable services agreement (including the content of messages of customer end users ("End User Communications")). inChat processes End User Communications under the instructions of the relevant customer, which is the "data controller" or "business" (or occupies a similar role as defined in applicable privacy laws), as described in the applicable services agreement between such customer and inChat inChat’s obligations as a "data processor" or "service provider" with respect to such information are defined in such services agreement and applicable data protection addendum and are not made part of this policy.
If you are a customer’s end user and you have questions about how your information is collected and processed through the services, please contact the organisation who has provided your information to us for more information.
What do we collect and why?
Our guiding principle is to collect only what we need. Here’s what that means in practice
For identity and access
When you sign up for an inChat product, we ask for identifying information such as your name, email address, and maybe a company name. That’s so you can personalize your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. With your consent, we will send you our newsletter and other updates.
We’ll never sell your personal information to third parties, and we won’t use your name or company in marketing statements without your permission either.
Billing information
If you sign up for a paid inChat product, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t hit inChat servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for service, calculate any sales tax due, send you invoices, and detect fraudulent credit card transactions. We occasionally use aggregate billing information to guide our marketing efforts.
Product interactions
We store on our servers the content that you upload or receive or maintain in your inChat product accounts. This is so you can use our products as intended, for example, to create chatbot deployments or dialogue on the inChat Platform. We keep this content as long as your account is active.
As regards our chatbot products (such as Weekdchat) we only collect personally identifiable information that is specifically and voluntarily provided by you. inChat receives limited identifiable information, such as name, Telegram username, email address, and telephone numbers, from chatbot users.
We do not capture demographic information, including gender or age. This information may be submitted when a user interacts with a chatbot product such as Weekchat. Our intention is not to capture sensitive information or special category data.
We suggest users do not venture this information. If you do wish to provide sensitive information for any reason, inChat accepts your explicit consent to use that information in the ways described in this privacy statement or as described when you choose to disclose this information.
Website interactions
We use Extellio.com to collect information about your browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us.
Cookies
We also use persistent first-party cookies and some third-party cookies to store certain preferences, make it easier for you to use our applications, and perform A/B testing as well as support some analytics.
A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data. You can adjust cookie retention settings and accept or block individual cookies in your browser settings, although our apps won’t work and other aspects of our service may not function properly if you turn cookies off.
Voluntary correspondence
When you email inChat with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.
We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.
When we access or disclose your information
To provide products or services you’ve requested. We use some third-party subprocessors to help run our applications and provide the Services to you.
In order to access and communicate with some of our chatbot products e.g. Weekchat, you will need to access WhatsApp (owned by Meta Inc.) or Telegram. Furthermore, in order to facilitate messaging on WhatsApp, the data you give the chatbot may be processed via Twilio (Twilio Inc.). Telegram, Meta and Twilio, our third party providers, operate the same standard of privacy protection that inChat does.
Our chatbot products use OpenAI and Huggingface API services in order to generate responses and for natural language processing capabilities. A limited number of responses or chatbot interactions may be submitted to these services for processing. Both providers operate at the same standard of privacy protection that inChat does. In neither case do we use services that use data for training machine learning models or store data for longer than 30 days.
Your personal information may also be transferred to other third party service providers who process information on inChat's behalf, including providers of information technology, identity management, website hosting and management, data back-up, security and storage services.
To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your content to help you with a support case, we will ask for your consent before proceeding.
To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.
Aggregated and de-identified data. We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.
When required under applicable law. inChat is a UK company and all data infrastructure are located in the UK.
- Requests for user data. Our policy is to not respond to government requests for user data unless we are compelled by legal process or in limited circumstances in the event of an emergency request. If law enforcement have the necessary warrant or court order requiring us to disclose data, we must comply.
- If we are audited by a tax authority, we may be required to disclose billing-related information. If that happens, we will disclose only the minimum needed, such as billing addresses and tax exemption information.
Your personal information is not shared with any third party, for any secondary or unrelated purposes unless otherwise disclosed at the point of collection. If there is an instance where such information may be shared, the user will be asked for permission beforehand.
This privacy notice does not apply to the practices of third parties that we do not own or control (such as Meta and Twilio), including but not limited to any third party websites, services and applications (“Third Party Services”) that you elect to access through our products or to individuals that we do not manage or employ.
While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.
How we secure your data
All data is encrypted via SSL/TLS when transmitted from our servers to your browser or medium of access. The database backups are also encrypted. In addition, we go to great lengths to secure your data at rest. Our production databases are secured behind firewalls. NB- most operational data are not encrypted while they live in our database (since they need to be ready to send to you when you need them).
Data retention
We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.
Your rights with respect to your information
By contacting us (see our contact details below), you may, at any time request:
- to rectify inaccurate Personal Data concerning you
- to complete incomplete Personal Data concerning you
- to erase or to restrict the processing of (certain) Personal Data relating to you
- to transmit your Personal Data to another controller or processor; and
- to cease the Processing of your Personal Data
- confirmation as to whether or not Personal Data concerning you are being processed by us and, where that is the case, you may request access to or receipt of your Personal Data
We will investigate whether it is feasible to respond to your request and whether we are legally obliged to do so. We will give you written confirmation about the chosen way forward.
Questions or complaints with respect to the processing of your personal data
In case you have any questions with respect to the Processing of your Personal Data, you can contact us team@inchat.deisgn.
Please note that you have the right to lodge a complaint with the ICO, which is the regulator for our processing of personal data at any time if you are of the opinion that the Processing of your Personal Data by inChat infringes the UK GDPR or other data protection laws.
Modification
We may update this policy as needed to comply with relevant regulations and reflect any new practices. inChat reserves the right to modify or amend this Statement at any time.
Adapted from the Basecamp open-source policies / CC BY 4.0