Privacy Policy

We collect personal data through three channels: (a) information you provide directly when creating an account or using the Service, (b) information automatically collected when you interact with the Service, and (c) information received from third-party services you connect to GlobVoice.

1.1 Account information

• Identity data: your full name, email address, business name, organisation name, and profile picture URL (when you sign in with Google OAuth).
• Authentication credentials: WebAuthn / passkey public credentials, two-factor authentication (TOTP) secrets in encrypted form, session identifiers, and security event metadata.
• Business information: business address, GSTIN where provided, industry vertical and team composition.
• Communication preferences: notification settings, language preference and timezone.

1.2 WhatsApp messaging data

• Recipient phone numbers that you upload via CSV, the contact import API, manual entry or chatbot interactions.
• Contact list metadata such as recipient names, tags, segments, opt-in source, opt-in timestamp and language.
• Message content sent to and received from your Recipients, including text, media (images, video, audio, documents), template variables, interactive button responses, location messages and contact cards.
• Voice messages received from Recipients, which may be transcribed to text using AI speech-to-text services to power our AI chatbot.
• Delivery and engagement data: message identifiers, timestamps, delivery status, read receipts, failure reasons returned by Meta and per-conversation pricing data.
• Opt-in and opt-out records: consent timestamps, STOP / unsubscribe signals and Meta block / report-spam signals.

1.3 Payment information

• Payments are processed by Razorpay Software Private Limited. Razorpay collects and processes your payment instrument data (card details, UPI handles, bank account details, net-banking credentials) directly. We do not see or store your full card number, CVV or banking credentials.
• We receive and store from Razorpay only: transaction identifier, last four digits of payment instrument, payment method type, amount, currency, status and billing address.

1.4 Information collected automatically

• Device and log data: IP address, browser type and version, operating system, screen resolution, timezone and referring URL.
• Usage data: features used, pages viewed, campaign actions, clicks, session duration and approximate location (city-level, derived from IP).
• Cookies and similar technologies: see Section 9 below.
• Security signals: sign-in attempts, IP changes, passkey registrations, suspicious-activity flags.

1.5 Information from third parties

• Google OAuth - when you sign in with Google, we receive your name, email address and profile picture URL per the OAuth scope you authorise.
• Meta / WhatsApp Business Cloud API - when you connect a WhatsApp Business Account, we receive an access token, phone number ID, WhatsApp Business Account ID, display name, message template status and quality rating.
• Razorpay - payment status and tokenised instrument metadata, as described in Section 1.3.

We use the personal data described in Section 1 for the following purposes, on the lawful bases set out under the DPDP Act (consent, certain legitimate uses, performance of contract, and legal obligation):

• Service delivery: to create and manage your account, authenticate you, provision your workspace and provide the GlobVoice product.
• WhatsApp messaging: to enqueue, send, track and report outbound WhatsApp messages on your behalf, and to receive, route and store inbound messages from your Recipients.
• AI chatbot and automation: to process inbound messages through our AI engine (see Section 6) so that we can return automated replies, suggest responses, route conversations and run AI-powered flows that you configure.
• Voice transcription: to transcribe voice messages received from your Recipients into text so that the AI chatbot can understand them.
• Campaign analytics: to compute delivery, read, click and conversion metrics for your campaigns and segments and to present them in your dashboard.
• Billing and payments: to process your subscription, generate invoices, apply taxes, prevent chargebacks, and meet our financial record-keeping obligations.
• Customer communication: to send product, billing and security notifications, respond to support requests and (with your consent where required) send product updates.
• Security and abuse prevention: to detect, prevent and respond to fraudulent activity, account takeover, spam, abuse, denial of service and other risks.
• Service improvement: to understand aggregate usage of the Service, debug errors and improve performance, reliability and user experience.
• Legal compliance: to comply with applicable Indian laws (including the Information Technology Act, 2000 and the DPDP Act, 2023), respond to lawful requests from authorities, and enforce our Terms of Service.

We do not use your Recipients' phone numbers or message content to market to them on our own behalf, and we do not sell personal data to any third party.

3.1 Where data is stored

GlobVoice application servers, databases (PostgreSQL), queues (Redis) and object storage are hosted in Hetzner Online GmbH data centres located in the European Union (primarily Germany - Falkenstein and Nuremberg). Hetzner is ISO 27001 certified and operates under the GDPR.

Some sub-processors used to deliver the Service (such as Meta Platforms, Inc. and our AI providers) may store or process data outside India and the EU. See Sections 4 and 11 below.

3.2 Encryption

• At rest: AES-256-GCM encryption is applied to all sensitive credentials we store, including Meta access tokens, two-factor secrets and API keys. Master keys are derived using the scrypt key-derivation function and held in environment-level secret storage that the application database cannot read directly.
• In transit: all traffic to and from GlobVoice is served over HTTPS using TLS 1.3 with modern cipher suites. Internal service-to-service communications use TLS or are bound to a private network.

3.3 Retention periods

• Account data: retained for as long as your account is active and for 12 months thereafter, unless a longer retention is required by law (for example, tax and accounting records are retained for 8 years under Indian law).
• Message content and conversation history:retained for as long as your account is active. After account closure, message data is permanently deleted within 30 days except where retention is required by law.
• Contact lists: retained until you delete them or until your account is closed.
• Billing and invoice records: 8 years from the end of the relevant financial year as required by Indian tax law.
• Security logs: 12 months.
• Backups: encrypted backups are retained for up to 35 days and rotate automatically.

You may request earlier deletion of your data at any time by writing to support@globvoice.com. We will action verified erasure requests within 30 days, subject to any overriding legal retention obligation.

We do not sell personal data to anyone. We do not rent, trade or otherwise transfer personal data for monetary or other valuable consideration. We share personal data only with the limited categories of recipients described below, each of whom is bound by appropriate confidentiality and data-protection obligations.

4.1 Sub-processors

• Meta Platforms, Inc. (WhatsApp Business Cloud API) - receives outbound message payloads (recipient phone number, template body, variables, media URLs) so that messages can be delivered to your Recipients over WhatsApp. Meta returns inbound webhooks and delivery status events. Meta acts as an independent controller under its own WhatsApp Business Messaging Policy and its own privacy policy.
• Razorpay Software Private Limited - processes your payments. Receives the data described in Section 1.3 and is regulated by the Reserve Bank of India as a Payment Aggregator.
• Groq, Inc. (AI inference) - receives inbound message content (text) when our AI chatbot is enabled, in order to generate a response. See Section 6.
• Google LLC (Gemini AI) - receives inbound message content when the Gemini model is selected by our smart router, in order to generate a response. Used also for OAuth sign-in.
• OpenRouter, Inc. - acts as a gateway to additional AI models for fallback and specialist tasks; receives message content only when those models are invoked.
• Hetzner Online GmbH - infrastructure hosting provider for our servers, databases, backups and object storage in the European Union.
• Email delivery providers - to send transactional emails (sign-in links, billing receipts, security alerts).

4.2 Legal disclosures

We may disclose personal data to courts, regulators, law enforcement and other public authorities where we are required to do so by a valid Indian legal process, or where disclosure is necessary to protect our rights, your safety or the safety of others, or to investigate fraud or security incidents. Where lawfully permitted, we will notify the affected Customer before disclosure so that the Customer may challenge the request.

4.3 Business transfers

If WENSLink is involved in a merger, acquisition, financing, reorganisation or sale of assets, personal data may be transferred as part of that transaction. We will notify Customers and require the acquirer to honour the commitments of this Policy.

GlobVoice connects to your WhatsApp Business Account via the official Meta Cloud API. The processing of WhatsApp data is the most sensitive activity we perform on your behalf, and we treat it with corresponding care.

5.1 What is processed

• Outbound: the recipient phone number, template name, language code, body variables and media references are transmitted to Meta's Cloud API endpoints over TLS so the message can be delivered.
• Inbound: incoming messages from Recipients are received via webhook, validated using HMAC-SHA256 signatures, persisted in our database (encrypted at rest), and routed to the configured chatbot flow, AI engine or human agent inbox.
• Voice messages: voice notes from Recipients are downloaded from Meta's media endpoints, transcribed to text by an AI speech-to-text service, and stored alongside the original audio reference.
• Contact phone numbers are stored in our database in plaintext (not hashed) because we must transmit them to Meta in order to send messages. Access is controlled by per-tenant database isolation (Postgres row-level security).

5.2 Our role

With respect to Recipient data, we act as a Data Processor on the documented instructions of the Customer. The Customer is the Data Fiduciary and is responsible for obtaining valid consent under Section 6 of the DPDP Act, the Meta WhatsApp Business Messaging Policy and any applicable opt-in rules under the Indian Telecom Commercial Communications Customer Preference Regulations, 2018 (TCCCPR) before uploading Recipient phone numbers to GlobVoice.

5.3 Meta's role

Meta Platforms, Inc. operates the underlying WhatsApp service and applies its own data policies to message metadata, delivery telemetry and abuse signals. Meta's processing is governed by the WhatsApp Business Policy, WhatsApp Business Terms and the WhatsApp Privacy Policy.

5.4 Opt-out and STOP handling

We honour STOP, UNSUBSCRIBE and similar opt-out signals from Recipients automatically. Once a Recipient opts out, their phone number is added to a per-tenant blocklist and no further messages of the relevant category are sent to them through GlobVoice. The audit trail of the opt-out is retained as evidence of compliance.

GlobVoice provides an AI chatbot engine and AI-assisted features (smart routing, voice transcription, multilingual responses, analytics summaries). To deliver these features, message content and limited context are sent to large language model providers for inference.

6.1 AI providers we use

• Groq, Inc. - low-latency inference of open-weight models for the default chatbot path.
• Google LLC - Gemini family of models, used by the smart router for higher-capability or multimodal tasks.
• OpenRouter, Inc. - aggregator for fallback or specialist models when the primary provider is unavailable.

6.2 What is sent to AI providers

• The current Recipient message (text) and a short window of preceding conversation turns required to maintain context.
• The system prompt, configuration and tools that the Customer has defined for the chatbot.
• A transcript of voice messages when voice-to-text is invoked.

We do not send your account credentials, payment details, full contact lists, other Customers' data or any data outside the scope of the active conversation.

6.3 No training on Customer data

We have configured our AI providers, where the provider supports it, to not use Customer or Recipient data for training, fine-tuning or model improvement. AI providers may retain inference inputs and outputs only for a limited period to detect abuse, after which they are deleted under the provider's policies.

6.4 Conversation history

We store the conversation history between the chatbot and your Recipient in our database (encrypted at rest) so that future messages have context and so that you can review and improve the chatbot. You may delete a conversation at any time from the inbox.

6.5 Limitations of AI output

AI responses are automatically generated and may be inaccurate, incomplete or unsuitable. They are not professional advice (legal, medical, financial or otherwise). The Customer is responsible for reviewing and configuring the chatbot, supervising its behaviour and complying with applicable consumer-protection law.

We maintain administrative, technical and physical safeguards designed to protect personal data against unauthorised access, disclosure, alteration or destruction. See our Security page for more detail. Selected highlights:

• Encryption: AES-256-GCM at rest for sensitive credentials; TLS 1.3 in transit.
• Authentication: WebAuthn / passkey authentication and Google OAuth. We do not store user passwords.
• Session management: HttpOnly, Secure, SameSite=Lax session cookies; short server-side session lifetimes; full revocation on sign-out.
• Tenant isolation: Postgres row-level security policies enforce that no tenant's query can return another tenant's data, even if application code is misconfigured.
• Access control: role-based access control inside the application; principle of least privilege for staff; access to production data is restricted to a small number of trained engineers and audited.
• Vulnerability management: dependency scanning, code review, secret scanning and periodic security testing.
• Webhook authenticity: all webhooks from Meta and from Customer-configured destinations are validated by HMAC-SHA256 signature.

No system is perfectly secure. In the event of a personal-data breach affecting your data, we will notify you and the Data Protection Board of India in accordance with the timelines prescribed by the DPDP Act and the rules made under it.

If you are an individual whose personal data we process - whether as a GlobVoice Customer or as a Recipient of one of our Customers - you have the following rights under the Digital Personal Data Protection Act, 2023:

• Right to access: obtain a summary of the personal data we hold about you, the purposes for which we process it and the categories of recipients with whom we have shared it.
• Right to correction: ask us to correct inaccurate or misleading personal data.
• Right to completion and updating: have incomplete data completed and outdated data refreshed.
• Right to erasure: ask us to erase personal data that is no longer necessary for the purpose it was collected, subject to overriding legal-retention obligations.
• Right to grievance redressal: raise a complaint with our Grievance Officer (Section 13). We will acknowledge within seven days and resolve within 30 days, in line with the DPDP Rules.
• Right to nominate: nominate another individual to exercise these rights on your behalf in the event of your death or incapacity.
• Right to withdraw consent: where we rely on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing performed before withdrawal, and may limit our ability to provide the Service.

To exercise any of these rights, please write to support@globvoice.com from the email address associated with your account or from an address we can reasonably verify is yours. We may need to verify your identity before responding.

If you are a Recipient of a GlobVoice Customer and you wish to exercise rights with respect to data uploaded by that Customer, please contact the Customer directly - they are the Data Fiduciary. We will assist the Customer in fulfilling your request.

GlobVoice uses only the minimum cookies necessary to run the Service. We do not run third-party advertising cookies and we do not use cookies to build a cross-site profile of you.

• Session cookie (HttpOnly, Secure, SameSite=Lax) - required to keep you signed in. Cleared when you sign out or when the session expires.
• CSRF token cookie - prevents cross-site request forgery on state-changing actions.
• Preference cookie - remembers UI choices such as theme and language. Non-essential.

Most browsers let you block or delete cookies. Blocking essential cookies will prevent you from signing in.

GlobVoice is a business product and is not intended for use by children under the age of 18. We do not knowingly create accounts for, market to, or process personal data of children under 18 without verifiable consent of a parent or lawful guardian as required by Section 9 of the DPDP Act.

If you believe a child has provided personal data to us, please contact support@globvoice.com and we will delete the data promptly.

GlobVoice infrastructure is operated from data centres in the European Union (Hetzner, Germany). Some sub-processors are located outside India:

• European Union: Hetzner Online GmbH (Germany).
• United States: Meta Platforms, Inc.; Groq, Inc.; Google LLC; OpenRouter, Inc.

Cross-border transfers are made (a) to countries the Central Government of India has not restricted under Section 16 of the DPDP Act, and (b) under appropriate safeguards including written data processing agreements with each sub-processor, Standard Contractual Clauses where applicable, and Meta's Data Processing Terms for the WhatsApp Business API.

We may update this Policy from time to time to reflect changes in our Service, our practices or applicable law. Material changes will be announced in-app and emailed to the account owner at least 14 days before they take effect. The “Last updated” date at the top of this page always reflects the current version. Your continued use of the Service after the effective date constitutes acceptance of the updated Policy.

For any privacy questions, data-subject requests, or grievances, please write to our Grievance Officer:

• Grievance Officer: Mr. Ataur Rahman, Founder & Director, WENSLink Private Limited.
• Email: support@globvoice.com
• Operations Office: L24 A South Ex, Delhi - 110049, India.
• Registered Office: Maa Commercial Complex, NH-15, Bechimari, Darrang, Assam - 784514, India.

We will acknowledge your communication within seven days and aim to resolve it within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Data Protection Board of India.