Effective Date: 10.03.2025

Popcorn Tech Ltd. (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, share, and protect your information when you use our website, products, and services (collectively, the “Services”). This includes interactions through our WhatsApp-powered conversational commerce platform.

1. Who We Are

Popcorn Tech Ltd. is a conversational commerce platform that enables businesses to engage customers, process orders, and run marketing campaigns through messaging channels.
Our services are designed for businesses, and we act both as a Data Controller (when handling business users’ information) and a Data Processor (when processing end-customer data on behalf of our clients).

2. What Data We Collect

a. Information You Provide

• Name, email, phone number
• Company details (name, industry, size)
• Billing and payment data
• WhatsApp Business API credentials
• Uploaded product catalogs and customer segments

b. Automatically Collected Data

• IP address, browser type, device ID
• Usage logs, feature interactions, and session data
• AI agent conversation logs

c. End-Customer Data (on behalf of clients)

• Message content and metadata
• Order history and customer behavior
• Identifiers from e-commerce platforms (e.g., Shopify, Zid)

3. How We Use Your Data

We use the data to:

• Deliver and improve the Services
• Train and enhance AI models (in a privacy-respecting manner)
• Monitor service usage and detect fraud
• Sync with e-commerce platforms for real-time updates
• Conduct analytics and ROI attribution
• Send transactional and marketing communications (with consent)

4. Automated Decision-Making and AI

Our AI agents use automated logic to provide responses, recommend products, and process orders.
These models learn from anonymized data and past interactions.
Human agents can override AI decisions upon request or escalation.

5. Legal Bases for Processing (GDPR)

We process your personal data based on:

• Contractual necessity (to provide the Services)
• Legitimate interests (e.g., service improvement)
• Consent (where required for marketing)
• Legal obligations (e.g., compliance requests)

6. Sharing and Subprocessors

We may share your data with:

• Hosting and infrastructure providers
• WhatsApp and other messaging platforms
• E-commerce integration partners
• Customer support and analytics tools

We maintain a list of authorized subprocessors at: [Insert Link]
All subprocessors are bound by confidentiality and data protection obligations.

7. International Transfers

We store and process data globally.
If data is transferred outside the EU/EEA, we use Standard Contractual Clauses (SCCs) or rely on other approved mechanisms.

8. Data Retention

We retain personal data only as long as needed:

• For the purpose it was collected
• To comply with legal or contractual obligations
• To improve AI models (in anonymized or aggregated form)

At this time, we do not support direct user-initiated data export or migration.

9. Security Measures

We implement:

• End-to-end encryption for message content
• Role-based access controls
• HTTPS and firewall protection
• Regular security audits

SOC 2 Type II compliance is on our roadmap. WhatsApp API compliance is maintained across our infrastructure.

10. Data Breach Response

In the event of a data breach, we will:

• Notify affected users within 72 hours
• Provide an impact assessment and mitigation steps
• Cooperate with legal authorities if required

11. Your Rights

Depending on your location, you may have the right to:

• Access your data
• Correct inaccurate information
• Request deletion of data
• Restrict or object to processing

To exercise these rights, contact: info@trypopcorn.ai

Please note that we currently do not support data portability or migration capabilities.

12. Cookies and Tracking

We use cookies to:

• Analyze traffic and usage
• Remember preferences
• Improve the website experience

You can manage cookies through your browser settings or our cookie preferences banner.

13. Children’s Privacy

Our Services are not intended for children under 13.
We do not knowingly collect their data.

14. Data Processing Agreement (DPA)

Our DPA forms part of our Terms of Service and outlines how we process personal data on behalf of our business customers.
A signed copy can be requested via [Insert Contact Email].

15. Changes to This Policy

We may update this Privacy Policy from time to time.
Changes will be posted on this page and, where appropriate, communicated via email or in-app notice.

16. Contact Us

Popcorn Tech Ltd.
DIFC, Dubai
Email: info@trypopcorn.ai

By using Popcorn AI’s Services, you acknowledge that you have read and understood this Privacy Policy.

‍