Privacy Policy
Draft for review. Items marked [CONFIRM] must be verified by CodeKubix (and ideally legal counsel) before this policy is relied upon or the Kayloq platform launches.
1. Who we are
Kayloq is a product brand operated by CodeKubix (“CodeKubix”, “we”, “us”). CodeKubix is the controller of personal information described in this policy. [CONFIRM: registered legal name, registration number and registered address]
2. Scope
This policy covers (a) this website, and (b) the Kayloq platform once it becomes available. The platform is currently in development; sections about the platform describe how we intend to handle data.
3. Information we collect
- Early-access and contact enquiries: name, email address, company (optional) and any message you send.
- Account and workspace data (platform): business and user account details, roles and settings.
- Contact data (platform): contact lists, tags, custom fields, segments and consent or opt-out status that our customers upload.
- Messaging data (platform): message content, templates, campaign data, conversation history and delivery statuses (sent, delivered, read, failed).
- Integration credentials (platform): tokens and identifiers needed to connect a customer’s WhatsApp Business account through Meta’s APIs. [CONFIRM: storage and encryption practices]
- Technical data: IP address, browser type and basic server logs for security and reliability. [CONFIRM: whether analytics or cookies are used]
4. How we use information
- To respond to enquiries and manage the early-access list.
- To provide, secure, support and improve the platform once available.
- To keep each customer’s workspace data separated from others.
- To comply with legal obligations and enforce our terms.
5. Our role for customer data
For contact and messaging data that businesses upload or process through Kayloq, the business is generally responsible for having a lawful basis and any required consent to message its contacts, and CodeKubix processes that data on the business’s behalf. [CONFIRM: data processing terms and roles]
6. Sharing
We do not sell personal information. We may share it with service providers that help us operate the service (for example hosting and email) and with Meta Platforms, Inc. to the extent needed to send and receive WhatsApp messages through its APIs, which is governed by Meta’s own terms and policies. We may also disclose information where required by law. [CONFIRM: list of sub-processors]
7. Retention
We keep information only as long as needed for the purposes above or as required by law. Early-access enquiries are kept until you ask us to delete them or the programme ends. [CONFIRM: retention periods]
8. Security
We use reasonable technical and organisational measures to protect information. No system is perfectly secure. [CONFIRM: specific controls before claiming any]
9. Your rights and choices
Depending on where you live, you may have the right to access, correct, delete or restrict use of your personal information, or to object to its processing. See our Data Deletion Instructions or contact us below. [CONFIRM: applicable jurisdictions and legal bases]
10. International transfers
[CONFIRM: hosting location and any cross-border transfer safeguards]
11. Children
Kayloq is intended for businesses and is not directed to children.
12. Changes
We may update this policy and will change the “Last updated” date when we do.
13. Contact
Questions or requests: raviverma.rs@hotmail.com